Michael Thomas (Pump Court Tax Chambers) highlights some areas of topical interest for VAT and real estate.
The purpose of this article is to highlight some areas of topical interest for VAT and real estate. Probably the most significant current development in tax is HMRC’s use of its Connect computer system to target groups of taxpayers and kinds of transactions. It has never been more important to get the technical analysis of transactions correct.
Transfers of going concerns
One area targeted recently by HMRC is the availability of transfer of a going concern (TOGC) treatment. Where this is available there are both cashflow benefits and an absolute SDLT saving available to taxpayers. With SDLT chargeable at 5% the SDLT saving can be considerable if a sale of land over which the option to tax has been exercised can be structured as a TOGC e.g. £500 000...
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Michael Thomas (Pump Court Tax Chambers) highlights some areas of topical interest for VAT and real estate.
The purpose of this article is to highlight some areas of topical interest for VAT and real estate. Probably the most significant current development in tax is HMRC’s use of its Connect computer system to target groups of taxpayers and kinds of transactions. It has never been more important to get the technical analysis of transactions correct.
Transfers of going concerns
One area targeted recently by HMRC is the availability of transfer of a going concern (TOGC) treatment. Where this is available there are both cashflow benefits and an absolute SDLT saving available to taxpayers. With SDLT chargeable at 5% the SDLT saving can be considerable if a sale of land over which the option to tax has been exercised can be structured as a TOGC e.g. £500 000...
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