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STAMP TAXES
Private client review for July 2024
Edward Reed
Kazia Gagg
Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for
private clients under the new Labour government and comment on a number
of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.
New guidance on 1.5% stamp tax charge and s 138 clearances
David Wilson
Jack Jones
After an uneventful Budget and Tax Administration and Maintenance Day, and with little by way of legislative proposals (except for those advising non-doms), some of the most interesting tax developments of recent months have come in the form of...
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
Financial services SDRT: it’s not you, it’s me
Suzi Evans
Many fear financial services SDRT. Suzi Evans (Alpine Edge Consulting) considers how the cause of that fear may not lie within the legislation.
What exactly is a ‘land transaction’ for SDLT purposes?
Paul Clark
John Shallcross
The meaning of ‘land transaction’ is more important than ever. Paul Clark (Cripps) and John Shallcross (Blake Morgan) explore the issues, with examples.
SDLT linked transactions: a long-term relationship
Leigh Sayliss
Leigh Sayliss (Memery Crystal) considers the effects that changes in one linked transaction can have on others.
The stamp duty lottery for alternative property finance providers
Sean Randall
The SDLT exemptions for alternative property finance need to be updated to give parity with conventional mortgages. Without change, SDLT will distort the market, warns Sean Randall (Blick Rothenberg).
Ask an expert: A case study on de-enveloping
Marc Selby
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.
The stamp taxes on shares modernisation: modern enough?
Richard Sultman
Peter North
While awaiting the outcome of HMRC’s consultation on stamp tax
modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider
some missed opportunities and unresolved issues.
Tax and the City review for October 2023
Mike Lane
Zoe Andrews
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
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54
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
Read all
Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
Read all
The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget