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CORPORATE TAXES


HMRC may have overlooked their own statement of practice which says that such a transfer is in general a disposal, writes David Whiscombe.
In the first in a series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) focus on the conditions for corporation tax loss relief via group relief.
Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.
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).
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining W&I insurance with other tools may help bridge any gaps in tax risk coverage and maximise protection for buyers.
Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.
Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT regime after two years of operation.
Card image Matt Cummings Colin Askew Alisha Kouser
Untangling a business from a group (or single entity) in a tax neutral fashion takes time and care. Colin Askew, Matt Cummings and Alisha Kouser (Eversheds Sutherland) provide a case study considering the tax issues on a partition demerger.
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