Corporate and International Tax

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…

A key advantage of a trade and asset purchase is that the purchaser is less likely to be exposed to inheriting historical liabilities in the target company on/post acquisition. By…

Many entrepreneurs have shareholdings in more than one business. Or they may own a trading business but also have investments – in property perhaps – held in another company. A…