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Share for share exchanges are regularly seen in various types of company sale and reorganisation transactions. Broadly, where a shareholder exchanges shares in Company A for shares in B, and…

Deeming provisions are common in tax provisions. As their names suggests, they ‘deem’ certain situations to satisfy specific conditions when they might not otherwise meet the strict wording of the…

As explained here, there has been a significant increase in recent years in individuals considering moving offshore before a business sale as non-UK residents are not subject to UK Capital…

M Group Holdings – Substantial Shareholding Exemption (“SSE”) – interpretation of paragraphs 15A and 26 of Schedule 7A Taxation of Chargeable Gains Act 1992 (“TCGA 92”). Issue -does it apply…

The cost of rented accommodation continues to rise. In London, the average monthly rent for a new tenancy is currently £2,109, representing an annual increase of 12.9%. Other major cities…

In the recent Upper Tier Tribunal joint cases of Laing O’Rourke Services Ltd and Willmott Dixon Holdings Ltd v HMRC, it was adjudged that car allowances paid to employees were…

If you are thinking ‘What?!!’ the likelihood is that you are not required to make payments on account. Taxpayers have to make two payments on account towards the final tax…

The R&D tax relief rates for R&D expenditure incurred after 1 April 2023 is changing. The changes are designed to ensure that the schemes provide better value for the UK…

From April 2023, qualifying companies will be able to issue Company Share Option Plan (CSOP) options to employees over shares worth up to £60,000 (double the current £30,000 limit) and…