CGT

Ritchie Tout

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...

Carolyn Steppler

Alice Martin

Alice Martin and Dr Carolyn Steppler (Charles Russell Speechlys) explain why excluding a settlor and spouse may not prevent CGT attribution after April 2025, and what reimbursement risks trustees must manage.

Veronika Lipinska

Matthew Emms

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

James Flint

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.

Ceinwen Rees

Caroline Inker

Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.

Maddy Potthast

Gavin Little

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.

Dominic Lawrance

Sophie Dworetzsky

Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).

David Whiscombe

HMRC may have overlooked their own statement of practice which says that such a transfer is in general a disposal, writes David Whiscombe.

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.