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CGT


Budget blues, legitimate expectation and crypto matters are among the issues reviewed by Sophie Dworetzsky (Lombard Odier).
Boulting cannot be regarded as a satisfactory case, except as to its outcome in favour of the taxpayer, writes David Whiscombe.
The Temporary Repatriation Facility could create significant tax savings for some. Alice Pearson (Mercer & Hole) highlights some practical considerations and areas of complexity.
Jo Bateson (Mercer & Hole) provides a practical guide to the new regime.

A detailed report of this year’s Finance Act.

FA 2025 Sch 6 introduces some fundamental and far-reaching changes to the Employee Ownership Trusts (EOT) tax rules. HMRC view the changes as pure anti-avoidance to provide them with the tools to counter the undoubted abuse of the EOT tax...
Matthew Emms and Veronika Lipinska (BDO) consider whether, following the 2025 Budget reforms, a CSOP should now revert to EMI, and in what circumstances CSOP or unapproved options might still be relevant.
Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.
Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.
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.
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