Many of our clients and readers will be familiar with the “loan to participator” rules. These rules apply to loans made by close companies, which in general terms are companies which are controlled by five or fewer participators (or by any number of participators who are also shareholders), to their
Share Buyback Qualified for Capital Treatment Where Undertaken for Genuine Trade Benefit
In Boulting v HMRC, the First-tier Tribunal (FTT) delivered a welcome decision for taxpayers on the tax treatment of a company purchase of its own shares.
The general rule is that when a UK-resident company purchases its own shares from a UK-resident shareholder, the shareholder is subject to dividend
Hotel La Tour Supreme Court Ruling: Final Confirmation on VAT Recovery for Share Sale Adviser Fees
In a unanimous judgment, the UK Supreme Court has given final confirmation that VAT incurred on adviser fees connected with an exempt share sale is not recoverable, endorsing the Court of Appeal’s strict application of the “direct and immediate link” test. The decision brings finality to an area that had
UK Budget – Some Key Changes
The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were new and surprising. We have summarized here of the most
UK Finance Bill 2019 published – UK commercial property tax regime for non-resident investors to change, but some relief for trading businesses
On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a consultation by HMRC following the November 2017 Budget
European Commission Publishes Anti Tax Avoidance Package
On 28 January 2016, the European Commission published a draft Anti Tax Avoidance Package in order to ensure increased tax transparency and effective taxation within, and outside of, the EU. The package includes a proposed Directive on tax avoidance practices (discussed further below), amendments to the Directive on automatic information