Corporate and International Tax

The United Kingdom’s exit from the European Union triggered significant changes in its tax and trade relations with EU member states and beyond. One area of particular importance is the…

There may be times when the UK interest expense of a UK company or group increases to above £2m and therefore, as a result, the CIR rules should be considered….

One method of migration is for an existing holding company or company to cease to be tax resident in one country and become tax resident in another. A UK incorporated…

It is nearly 7 years since the corporate losses reforms were introduced from 1 April 2017, which included the concept of ‘carry forward’ group relief.  Prior to 1 April 2017,…

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…

As our corporate finance friends will tell you, you can’t just wake up one morning and decide to sell your business. Well, you can, but you probably won’t get the…

Being in my third decade as a corporate tax adviser, I’ve seen a few Chancellors come and go, and with them, a whole host of tax rate changes. Whilst it’s…

From 1 April 2023, the rate of Corporation Tax (CT) increased from 19% to 25%. However, the lower rate of 19% can still apply, dependent on the level of “augmented profits”…

In December 2021 HMRC published a draft version of The Transfer Pricing Records Regulations 2023 for consultation. The draft regulations require Multinational Enterprises (“MNEs”) with turnover of €750m or more, to…