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CGT
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CGT
CGT
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
Time is tight: CGT and the Autumn Budget
Peter Rayney
Peter Rayney (Peter Rayney Tax Consulting) discusses some strategies for
CGT tax planning in readiness for the upcoming budget.
Partnerships and SP D12
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).
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
Back to basics: Sale of assets at under value
Sadiq Hashmi
Ben Handley
A back to basics guide, by Ben Handley and Sadiq Hashmi (BDO).
Tax and the City review for October 2023
Zoe Andrews
Mike Lane
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
Back to basics: Section 260 holdover relief
Paul Townson
Sophie Mehta
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
Back to basics: Section 165 holdover relief
Paul Townson
Chris Holmes
Chris Holmes and Paul Townson (BDO) provide a back to basics guide on this valuable relief.
Slade: land owning dispute costs not allowed
Julie Butler
Fred Butler
Julie Butler and Fred Butler (Butler & Co Alresford) examine an FTT case that denied a deduction for legal expenditure incurred defending rights to a number of assets ‘collectively’ when one of those assets was sold separately.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
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HMRC manual changes: 19 September 2025
Chancellor commits to business rates reform
CIOT warns of ‘unintended complexity’ in APR/BPR draft legislation
Professional bodies analyse draft Finance Bill legislation
Changing the timing of land remediation relief may prove beneficial, says CIOT
CASES
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The Prudential Assurance Company Ltd v HMRC
P Collingwood v HMRC
K (oao Hotelbeds UK Ltd) v HMRC
Other cases that caught our eye: 19 September 2025
SC Arcomet Towercranes SRL
IN BRIEF
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Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
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Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
The hidden costs of a cap on lifetime gifting