Michael Hunter sets out some of the main issues to be thought through when advising on a capital contribution. He focuses on the risk of the contribution being taxed as trading income and on the tax treatment of the person making the contribution.
Martin Mann answers a query on the receipt of an earn-out by a sole shareholder of a holding company selling a trading subsidiary.
Tony Beare comments on the draft guidance in relation to the meaning of ‘the intentions of Parliament’ and on the draft legislation dealing with breaches of the code.
As part of the consultation process (for the consultation on taxation of corporate debt and derivative contracts, which closed on 29 August), HMRC established four working groups of representatives from businesses, business advisers and others interested in the proposed reforms.
Accountancy firm Deloitte has reported that on 1 October, the tax committee of the Business and Industry Advisory Committee (BIAC) to the OECD had a meeting with the OECD to discuss the ongoing base erosion and profit shifting (BEPS) project.
In this comprehensive, seven-page report – which can be downloaded as a PDF – David Jervis, Ben Jones and Elspeth Van den Brande provide a detailed review of the tax deductibility rules across various European jurisdictions.
Jeff Webber answers a query on ATED property rental business relief.
A look at what’s ahead this month, with views from practitioners on what’s in their in-tray: David Whiscombe explains why it is another busy month for those advising SMEs; David Harkness warns on annual payments, ‘an anachronism for commercial transactions’; and Daniel Lyons highlights the uncertainty over aggregates levy exemptions faced by businesses.
Bill Dodwell considers the proposed anti-avoidance measures tackling transfer pricing ‘compensating adjustments’.