CAPITAL-GAINS

The UK currently treats sovereign immunity as a principle of international law under which one sovereign state cannot impose its laws, including its tax laws, on another sovereign. Accordingly, all UK source income and gains received by a sovereign...

David Martin

With capital gains tax once again under scrutiny, former practitioner David Martin considers the principles that should underpin reform, from lower rates and rollover relief to the relationship between CGT and income tax.

Payments to an Ireland government agency were not deductible under the loan relationship rules

Upper Tribunal rules on payments under LLP ‘capital interests’ and the mixed member partnership rules

Purchase of own shares benefited company’s trade

Maddy Potthast

Gavin Little

Continuing the series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) explain the rules for capital gains groups and the pitfalls to watch out for in practice.

Andrew Howard

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...

Artem Vasyutin

Sophie Hatton

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

Heather Self

Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).

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