GROUP-RELIEF

In the first in a series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) focus on the conditions for corporation tax loss relief via group relief.

Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.

Helen Coward (Charles Russell Speechlys) examines the decision in The Tower One St George Wharf Ltd concerning the SDLT group relief anti-avoidance rule.

A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).

Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a refresher guide to what must be among the most complex of all the SDLT rules.

Two recent decisions have sought to clarify the extent to which the EU freedom of establishment and of the movement of capital were restricted in light of various UK legislative provisions dealing with cross-border transactions and/or operations, as Dominic Stuttaford and Greg Branagan (Norton Rose Fulbright) explain.

Bridget English and Richard Sultman (Cleary Gottlieb Steen & Hamilton) discuss the proposed extension of the stamp duty/SDRT market value rule.

From 1 April 2017, there will be a substantial change to how corporation tax losses can be carried forward. Ben Jones and Dean Andrews (Eversheds Sutherland) examine the detail.

 

Sandy Bhogal (Mayer Brown) examines a recent tribunal case on whether certain insolvency procedures amount to a change of control for group relief purposes and looks at the potentially significant ramifications.