CGT

Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin)...

Michael Thomas KC

Diversifying ownership will become an increasingly important strategy in light of the new restrictions to APR and BPR, writes Michael Thomas KC (Pump Court Tax Chambers).

Tanja Velling

Alex Sim

A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and Tanja Velling (Slaughter and May).

Liz Hunter Nicola Simmons Moustapha Hammoud

Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya) explain the personal, employment and corporate tax issues.

Entrepreneurs’ relief claim allowed.

David Pett

David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider what is in the best interests of the beneficiaries as a class, how the sale proceeds are to be distributed and the tax consequences of any sale.

FTT rejects transitional provision carried interest appeals.

Bonus arrangements were fully taxable: Lynx Forecourt Ltd v HMRC [2024] UKFTT 278 (TC) (27 March 2024) is an appeal that relates to bonus arrangements put in place as far back as 2003. They were designed to exploit the rules which existed at the...

Preparatory steps insufficient to crystalise disposal for CGT purposes

Follower notices and penalties: R Baker v HMRC [2024] UKFTT 126 (TC) (6 February 2024) is the second case in which the tribunal has allowed appeals against penalties under the follower notice regime arising from the taxpayer participating in a scheme...

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