CAPITAL-GAINS

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

Purchase of own shares benefited company’s trade

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...

Sophie Hatton

Artem Vasyutin

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).

Martin Shah

Martin Shah (Simmons & Simmons) reviews the proposed reserved investor fund regime, while Melville Rodrigues (Apex Group) says why it is needed.

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Julia Lloyd

Susie Brain

Julia Lloyd and Susie Brain (Norton Rose Fulbright) provide an overview of the new regime and suggest practical steps that should be taken by taxpayers.

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