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CGT
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CGT
CGT
Dealing with non-resident CGT issues on transactions
Akash Mehta
Jenny Doak
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key
considerations for M&A transactions.
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
Time is tight: CGT and the Autumn Budget
Peter Rayney
Peter Rayney (Peter Rayney Tax Consulting) discusses some strategies for
CGT tax planning in readiness for the upcoming budget.
Partnerships and SP D12
Alex Sim
Tanja Velling
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
Back to basics: Sale of assets at under value
Sadiq Hashmi
Ben Handley
A back to basics guide, by Ben Handley and Sadiq Hashmi (BDO).
Tax and the City review for October 2023
Mike Lane
Zoe Andrews
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
Back to basics: Section 260 holdover relief
Paul Townson
Sophie Mehta
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
Back to basics: Section 165 holdover relief
Paul Townson
Chris Holmes
Chris Holmes and Paul Townson (BDO) provide a back to basics guide on this valuable relief.
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
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C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
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A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
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Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
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