CGT

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

Peter Vaines

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Andrew Constable

While 2024 has not exactly been plain sailing for SMEs, the tax related developments have not been as radical or fundamental as might have been feared, writes Andrew Constable (Mercer & Hole).

Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin)...

Michael Thomas KC

Diversifying ownership will become an increasingly important strategy in light of the new restrictions to APR and BPR, writes Michael Thomas KC (Pump Court Tax Chambers).

Tanja Velling

Alex Sim

A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and Tanja Velling (Slaughter and May).

Liz Hunter Nicola Simmons Moustapha Hammoud

Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya) explain the personal, employment and corporate tax issues.

Entrepreneurs’ relief claim allowed.

David Pett

David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider what is in the best interests of the beneficiaries as a class, how the sale proceeds are to be distributed and the tax consequences of any sale.

FTT rejects transitional provision carried interest appeals.

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