Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.
In light of the Upper Tribunal’s recent decision which took a restrictive view of the substantial shareholding exemption rules, a change to the legislation is now required, writes Alistair Godwin (EY).
The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
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