Gareth Miles and Greg Price (Slaughter and May) consider what the abolition of relief for acquired goodwill tells us about UK corporate tax policy-making and look at the practical implications for commercial transactions.
The funny thing about loopholes is that they can appear from nowhere.
In the world of UK tax the basic proposition is this: if the same transaction can be achieved in different ways it does not follow that each alternative must be taxed in the same way. So where:
an airline replaces its fleet by purchasing new aircraft outright (funded by debt equity or both) or by leasing them or by entering into a finance sale and leaseback; or
a hairdresser sets up in business as a sole trader or in partnership with others or as an employee of a corporate vehicle;
the objective of each option...
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Gareth Miles and Greg Price (Slaughter and May) consider what the abolition of relief for acquired goodwill tells us about UK corporate tax policy-making and look at the practical implications for commercial transactions.
The funny thing about loopholes is that they can appear from nowhere.
In the world of UK tax the basic proposition is this: if the same transaction can be achieved in different ways it does not follow that each alternative must be taxed in the same way. So where:
an airline replaces its fleet by purchasing new aircraft outright (funded by debt equity or both) or by leasing them or by entering into a finance sale and leaseback; or
a hairdresser sets up in business as a sole trader or in partnership with others or as an employee of a corporate vehicle;
the objective of each option...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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