The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).
HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
Julie Howard and Kyra Motley (Boodle Hatfield) consider the options for both structuring and financing the ownership of UK residential property in the face of recent greater taxation and compliance burdens.
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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