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Tax grouping (part II): capital gains groups
Maddy Potthast
Gavin Little
Continuing the series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) explain the rules for capital gains groups and the
pitfalls to watch out for in practice.
Private client review for February 2025
Dominic Lawrance
Sophie Dworetzsky
Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
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
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).
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).
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EDITOR'S PICK
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
1 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
2 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
3 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
4 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
5 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
6 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
7 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
NEWS
Read all
HMRC manual changes: 28 February 2025
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Business rates relief for film studios
HMRC advisory fuel rates
Scottish landfill tax rates
CASES
Read all
The executors of L Elborne deceased and others v HMRC
Chelsea Cloisters Management Ltd v HMRC
HMRC v Asset House Piccadilly Ltd
Other cases that caught our eye: 28 February 2025
A Taxpayer v HMRC
IN BRIEF
Read all
Statutory residence: but why do you need to be here?
Ramsay reined in?
HMRC’s focus on PE firms’ VAT compliance
HMRC’s U-turn on limited partners
Salaried members update
MOST READ
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
Finance Bill 2025 progress
Sonder Europe and serviced apartments: TOMS or no TOMS?
B Joseph v HMRC