Corporate and International Tax

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…

This seal of approval can be obtained by submitting a clearance application to HMRC in advance to confirm the tax treatment of a transaction or event, where possible. Obtaining clearance…

As the tax rate on dividends increased from 32.5% to 33.75% on 6 April 2022, the amount of the s455 tax charge on an overdrawn DLA will also increase to…