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Tax grouping (part II): capital gains groups
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.
Private client review for February 2025
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).
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
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.
Tax and the City review for January 2025
Mike Lane
Zoe Andrews
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.
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
Dealing with non-resident CGT issues on transactions
Akash Mehta
Jenny Doak
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key
considerations for M&A transactions.
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
Alex Sim
Tanja Velling
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).
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EDITOR'S PICK
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
1 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
2 /7
The new Securities Transfer Tax: business as usual?
Georgina West
3 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
4 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
5 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
6 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
7 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Perenco UK Ltd v HMRC
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?