SALE-OF-SHARES

Jeremy Webster (Pinsent Masons) answers a query on a sale of a business by way of hive down and subsequent share sale.

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.

Andrew Loan

Andrew Loan (Macfarlanes) reviews Prowting Trustees v Amos-Yeo concerning the rectification of a share transfer allowing a disposal to qualify for entrepreneurs’ relief, and considers the impact of inadvertent mistakes failing to achieve the desired tax result.

Andrew Levene

Andrew Levene (BKL) answers a query on the sale of residential property owned by a company.

Thomas Dalby

Thomas Dalby (Gabelle) answers a query on a client company with shareholders that have unequal holdings but agreed to split the proceeds of sale equally

Adam Craggs

Adam Craggs (RPC) takes a look at the First-tier Tribunal decision in Rotberg, and the extent of the tribunal’s jurisdiction

Emma Hardwick

Emma Hardwick considers the point during sale negotiations at which a target may lose the ability to surrender or receive group relief

Malcolm Pengelly

Malcolm Pengelly answers a query on when a holding company is dormant

Nigel Giles

Nigel Giles answers a query on the taxation of a redemption premium.

Paul Howard

In the case of HMRC v Sir Alexander Fraser Morrison, the Upper Tribunal found that a payment made in settlement of a High Court action was not a contingent liability under TCGA 1992 s 49, thus overturning the decision of the First-tier Tribunal. Paul Howard examines what this would mean in similar situations.

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