Tax Expert’s Offshore Savings Warning

Pete gives offshore savings warning in this piece from the Leicester Mercury saying, “Most people won’t need to worry and there’s nothing wrong with having savings offshore.  The ‘crime’ is to have offshore savings out of money that you have hidden from the UK taxman.”

To find out more please read this article here: https://www.themillerpartnership.com/wp-content/uploads/Leicester-Mercury-05.01.16-2.pdf

Posted in Uncategorized

Regional tax centres just a cost-cutting move

Pete expressed strong feelings regarding the news that MH Revenue and Customs was to shut all but 17 of its 160 offices saying, “… the plan is utter nonsense.  The move is essentially a cost-cutting exercise and has much more to do with saving money than improving efficiency.”

You can read more here: https://www.themillerpartnership.com/wp-content/uploads/Leicester-Mercury-1st-December.pdf

Posted in Uncategorized

It’s a funny old business

Pete of The Miller Partnership was one of the very brave souls who took to the stage for a five minute stand-up routine as part of Leicester Comedy Festival’s Stand-up Challenge.  The report says, “[Pete] did the seemingly impossible by making tax funny”.  He was rather good!

Read more.

Posted in Uncategorized

Dividend tax changes represent genuine tax rise for hard-working small businesses

When the Chancellor announced changes to how dividends are taxed in his Summer Budget, it was suggested there would be no tax increase, except for people receiving dividends of more than £140,000 a year.

This reassurance always seemed unlikely however, and HMRC’s recent explanation as to how the new tax system would work proves our point.

In fact the new regime represents a genuine tax rise for many people. The Conservative Party’s first solo Budget in many years delivers a kick in the teeth for entrepreneurial small businesses and is not an incentive for them to work harder and strengthen the UK economy

Under the current system, if you pay yourself a salary from your company of less than £10,600, the current personal allowance, and take the rest of your income in dividends, you will not pay any Income Tax on salary or dividends until your total pay exceeds £42,385.  

Under the new rules this will no longer be the case, from 6 April 2016.  Apart from your personal allowance, the first £5,000 of dividend income will be tax-free, after which all further dividends will be taxed at a minimum rate of 7.5 per cent.  So somebody paying themselves £42,385 out of their own company would have £15,600 tax-free (£10,600 personal allowance and £5,000 dividend allowance) with the next £26,785 taxed at 7.5 per cent, giving a tax bill of £2,008.88. (Actually, the personal allowance for 2016-17 will be £10,800, so the tax bill will be £15 less, at £1,993.88).

This might not seem much, but it is £2,088.88 more than under the current regime.  If your income exceeds £42,385, dividends will be taxed at 32.5 per cent on top of the £5,000 allowance, and if you are a high earner with more than £150,000 a year, the rate of tax on dividends will be 38.1per cent.  This is an Income Tax rate increase   on dividends of 7.5 per cent at every level.  It is a major tax increase for everybody –particularly small business owners who have traditionally paid themselves a small salary and large dividends.

The new system has been put forward as a form of tax avoidance measure, to discourage people from incorporating their business to take advantage of lower rates of Corporation Tax.  The current headline rate of Corporation Tax is 20 per cent but set to fall to 18 per cent over the life of this Parliament, compared with Income Tax rates of up to 45 per cent with National Insurance contributions on top.  

As mentioned, most dividends are paid by small owner managed companies and represent the profits of the average entrepreneurial small business person.  So many people perceive this measure as an extra tax charge on the small business person to pay for the lower Corporation Tax rate which favours some of the very largest companies in the country.

In contrast, while the drop in Corporation Tax rates is intended to encourage inward investment by multinationals, the headline rate of Corporation Tax is actually a relatively minor part of the decision-making process when choosing whether or not to invest in a given country.  It comes well down the list after other considerations such as infrastructure and access to an educated and motivated workforce.  In any case, the UK already had the joint lowest Corporation Tax rate in the G20 group of countries and it seems unlikely that a 1 per cent drop in the rate will make a material difference as to whether or not companies invest in the UK.

What we in business would much prefer to see are tax cuts for hard-working entrepreneurial business owners, not tax rises, so that people can retain more of their hard-earned profits and spend them in a way that enhances the economy, rather than paying more tax to the government.

The Miller Partnership has many years’ experience dealing with small business remuneration issues, and Pete was the Inland Revenue’s in-house expert on dividends.

For further advice or assistance please contact Pete on 0116 208 1020 or email pete.miller@themillerpartnership.com

 

The search to find Leicestershire’s wittiest businessman or woman has attracted a broad range of contestants.

The search to find Leicestershire’s wittiest businessman or woman has attracted a broad range of contestants.

The people behind Dave’s Leicester Comedy Festival are organising the 2015 Stand Up Challenge and looking for eight participants to sign up.

So far, around half that number have come forward.

Read more: http://www.leicestermercury.co.uk/ve-good-jokes-ambition/story-27493281-detail/story.html#ixzz3hD0DQKhU

Budget changes

In this article Pete from The Miller Partnership gives broad approval to Budget changes saying, “This is designed to make the UK more competitive but, if it is intended to encourage inward investment, it misses the mark, as the main beneficiaries will be the huge majority of small companies that are incorporated in the UK, anyway.”

Read more here: https://www.themillerpartnership.com/wp-content/uploads/lm110715.pdf

Leaky Business

The recent decision of the First-tier Tribunal in Leekes Ltd (TC4298) throws light on the requirement to stream trading losses when one company succeeds to the lossmaking trade of another. It is, significantly, the first case on this subject since Falmer Jeans Ltd v Rodin 63 TC 55 in 1990.

View the full article here.

The Finance Act 2015: What its changes to entrepreneurs’ relief mean for small business growth and why the newly returned government should consider revising the rules as soon as possible.

The Finance Act 2015 has made major changes to entrepreneurs’ relief which will undoubtedly have a major impact on the growth of many small businesses.

One of its measures will restrict the availability of this relief when transferring goodwill on incorporation.

The other will limit the availability of tax deductions for the amortisation of goodwill transferred to the successor company on incorporation.

Both these changes, in our opinion, are ultimately bad for business and have been ill thought through.

When a sole businessman or woman, or a partnership, has reached a certain size, it is often sensible to transfer the business into a company (a process called incorporation).

If the trade is transferred to the company in return for shares, there is a relief to prevent any capital gains tax arising. Alternatively, if the business has a trade that could be sold to a company, the sale would generate a capital gains tax charge of just 10% (under the entrepreneurs’ relief). But why would you do that?

If you price your business’s goodwill at £100,000 and sell it into a company, the £100,000 gain will carry a tax charge of £10,000, which you won’t need to pay until January 31 2017.

The new company does not have any money, so it now owes you £100,000, which it can repay as it makes profits, and there is no further tax on the repayment of a debt. So, for the sake of paying £10,000 tax on incorporation, you are able to take £100,000 out of the company tax free – in contrast to the income tax and National Insurance contributions payable on salaries or the income tax on dividends.

Unfortunately, HMRC closed down this opportunity on December 3 2014. This means that most incorporations will use the special tax reliefs. Rather more unfortunately, this legislation potentially reduces the opportunity for people to retire from a business and sell that business in a sensible way.

Let’s imagine that Paul and Art want have a song-writing partnership and Art wants to retire. Paul agrees to set up a company to buy the business from both of them. Paul incorporates using the relief mentioned above and Art agrees that the company will pay for his share out of future profits. Art will claim entrepreneurs’ relief at the 10% CGT rate. So far, so good, as the new legislation does not cause a problem.

However, difficulties arise if Art and Simon are closely related, such as brothers or father and son, for example. In such cases, because they are related, the new rules do not allow Art to retire from the trade and claim entrepreneurs’ relief. There is no apparent policy reason for this, and it is largely a problem caused by rushing the legislation through with no time for consultation.

Similarly, if Art is a sole trader and sells to his friend Paul’s company, Simon Ltd, Art can sell his business and, we hope, claim entrepreneurs’ relief at the 10% CGT rate. Again, this works unless Paul requires Art to take, say, a 5% shareholding in Simon Ltd. In that case, Art will not receive entrepreneurs’ relief, simply because he becomes a shareholder in the company, even though it is only a very small shareholding.

Again, there is no policy reason behind this restriction: it is just a lack of time to consult. In our view these changes to the Finance Act are too wide and will inhibit commercial transactions.

The other major change is that, whichever method is used to incorporate the company, it will not be allowed a tax deduction when it writes down the goodwill in its accounts if any member of the previous partnership is a shareholder in the company. In many cases, this was a generous relief that we might not be able to afford in austere times. But this change was also not adequately consulted on and leaves some major commercial unfairness that needs to be resolved.

The government responsible for these changes now has the opportunity to review them as it sets out its agenda for business for the next five years. In the interest of supporting growth of UK small businesses I sincerely hope it will revisit the Finance Act’s contents at its earliest opportunity.

In the meantime, we have been looking at ways in which the effects of these changes can be mitigated with longer term retirement planning. So, if you have clients looking to incorporate their business or to retire from partnerships, please get in touch to see if we can help.

Comment on the tax implications of the Chancellor’s Autumn Statement by Pete Miller, tax consultant with The Miller Partnership, Leicester.

The Chancellor’s Autumn Statement refers to backing business and enterprise, and to ‘taking further action to tackle tax avoidance, and to ensure that all businesses and individuals pay their fair share’ which are laudable aims. But does it deliver? Part of the answer, of course, depends on what you think is a ‘fair share.’

On the plus side, for innovative companies there is an enhancement to the tax reliefs for research and development from April 1 2015. The relief for small and medium companies will increase from 225% to 230%, and the special ‘above the line’ credit for large companies goes up to 11% from 10%. And the claim process is to be simplified by the introduction of an advance clearance procedure so that companies know in advance that they qualify. This increase should be helpful and may partly counter the recent announcement of the restriction of the patent box relief, which will close to new entrants from 2016 and close completely in 2021. But the expenditure that qualifies for Research & Development allowances is being restricted, which makes the changes look less generous overall.

We are also promised a new relief for production of children’s programmes and consultation about a relief for investment in orchestras. These may be nice things to have but they are a bit marginal in the grand scheme of things. The phrase ‘bread and circuses’ springs to mind!

There is a lot more on the minus side. Apparently, individuals and partnerships are ‘gaining an unfair tax advantage’ by incorporating businesses into a company and claiming Corporation Tax deductions for goodwill. This is abolished immediately, as HMRC says this is ‘an unintended tax benefit’, which is frankly not true. The deduction for goodwill has been in place for 12 years and has never been considered offensive or unintended and it is hard to see where this announcement has come from. It is certainly not a change that is ‘backing business and enterprise’, as it takes away an incentive to incorporate a business, which is a necessary commercial step on the growth curve.

Also with immediate effect, if you incorporate your business you will not be able to claim Capital Gains Tax Entrepreneurs’ Relief on the gain on transferring goodwill and similar assets into the company. This is another ‘anti-avoidance measure’, although it may be counter-productive, as it will reduce the immediate CGT yield as people use the CGT Incorporation Relief and do not pay any CGT on incorporating their business, instead of 10%.

A couple of other things worth mentioning are, firstly, a restriction on the use of trading losses by banks. The idea is that banks’ bad behaviour caused the current economic problems, so why should they be given tax relief for the losses they made? From April 1 215, banks will only be able to use losses to reduce their profits by 50%. Secondly, we have the so-called ‘Google tax’, a Diverted Profits Tax of 25% on profits diverted overseas by artificial arrangements. This might be a popular idea but it is hard to see how this will fit with the UK’s Treaty obligations, EU law, and other international factors.

Succession Planning

There comes a point in the life of every business when the owner decides to step down and sell the company.

As we saw in last month’s blog, you will want to make sure that you only pay capital gains tax at the 10% rate (the ‘entrepreneur’s relief’), when you sell a trade or trading company. But there may be further complications.

First of all, who are you selling to? You may structure a transaction differently if it is to a third party, to a management team, or to your children, or even to a mixture of any two or three of these. If a third party is willing to pay cash on day one, then you can simply walk away, worry free. But often your buyers won’t have the money to pay up-front, particularly in the case of a management buy-out or a sale to your children or other family members, so you may need some kind of structured disposal.

Typically, in these cases, the people wishing to buy the business will form a company (the ‘BidCo’). Let’s imagine the buyers are your management team:

BidCo buys your trading company for a mixture of cash, loan notes, and sometimes shares issued by BidCo. The cash element may come from the amounts subscribed for shares in BidCo by the management team, or from dividends paid by the acquired company to BidCo immediately after the acquisition. Either way, assuming you have a trading company and you otherwise qualify for entrepreneur’s relief, you will generate a 10% tax bill on the cash element, that capital gains tax being payable on January 31 after the next April 5 (so 31 January 2016 for transactions completed on or before 5 April 2015).

Generally, the CGT liability on the loan note element, or shares, only arises when the loan notes are redeemed or the shares are sold. However, it is important to ensure that redemption of the loan notes or sale of the shares in BidCo will also qualify for the 10% CGT rate. If, for example, you are only issued with loan notes and cash, the loan notes will not qualify for entrepreneur’s relief, as this relief requires you to hold at least 5% of the shares in the company. So if you are not receiving shares, you will need to make an election that says your CGT charge crystallises on the sale, not on the later redemption of the loan notes.

You must also make sure that you have the cash available to pay the January 31 tax bill. To do that the loan notes must be at least partly redeemable before that date.

This special treatment of shares and loan notes can be confirmed by a clearance from HMRC. This important process affords some degree of certainty over the tax treatment of your disposal and is best done for you by an experienced advisor.

We can also add other features to a buy-out. For example, in a case where parents were selling to their children in return for loan notes, the parents remained on the company’s board, partly to guide the children through the transition into full ownership, and partly to protect their investment until the loan notes were redeemed.

We are currently working on a phased management buy-out, with BidCo acquiring just over 25% of the company in the first instance, 25% later on, and then buying out the remainder with bank financing within about five years.

This gives just a brief overview of some of the issues that arise on structured disposals of your business, and highlights the need to speak to an experienced advisor on these matters.

Entrepreneurs’ Relief – The 10% Tax Rate!

It is a ‘well known fact’ that when you sell your business you will only pay Capital Gains Tax at 10%.

This is the so called Entrepreneurs’ Relief. Unfortunately, like all well known facts, there is more to this story. The tax rules are complex, and not entirely logical, so let’s take a look at the areas where you might be at risk of paying tax at the full rate of 28%.

Probably the most important feature of the Entrepreneurs’ Relief is that it only applies to trading companies. Unfortunately, there is no definition of what constitutes a trade and the decisions of the courts over the past 160 years have not always been helpful.

In most cases it is clear that you have a trade if, for example, yours is a retail operation or a manufacturing business, so it’s perhaps easier to discuss what does not qualify for the relief.

In general terms, concerns such as property investment businesses or, indeed, any other business which relies solely on passive investment income, would be exempt. Cases on the margins would include enterprises such as caravan parks, which HMRC generally considers to be investment businesses, even where the owners carry out related activities, such as providing utilities or other facilities.

If you’re a sole trader or carry out your trade through a partnership, then when you sell your trade or the partnership rights you should qualify for Entrepreneurs’ Relief.

The situation gets more complicated, however, if you trade through a company.

To be eligible for the relief, firstly you must own at least 5% of the company’s ordinary shares and hold at least 5% of the voting power in the company. Secondly you must be an employee or officer (director) of the company, or of a company within the group, if you have more than one company. As long as these conditions have been satisfied for a full year immediately before the sale, selling the shares, or any proportion of them, you should qualify for the 10 per cent tax rate.

However, problems can arise in instances where employees receive shares that were not voting shares, or where the company is co-owned by both husband and wife but where the wife has never been a director or employee of the company.

Another pitfall can emerge when accepting a loan document rather than an immediate cash payment from the purchaser of your business. This type of “share exchange”, can lead to difficulties, as any cash you receive when you sell the shares may qualify for the Entrepreneurs’ Relief, but the later redemption of the loan notes will not – so you might end up paying tax at 28% every time you redeem a loan note.

Breaking up’s not hard to do!

Apologies to Neil Sedaka, but have you got clients in business together who would like to separate their interests?  They may have fallen out or want to take the businesses in different directions, or perhaps they just want to split the businesses because of different risk profiles.  At the Miller Partnership we have extensive experience of splitting companies and groups into two or more parts, taking advantage of all the relevant tax reliefs and obtaining clearance in advance from HMRC.  We can carry out these demergers by any of the known mechanisms – distribution in specie, liquidation or reduction of capital – and we can advise you which one best fits your commercial needs.

Recently successes include:

  • Splitting an interior design trade, where the owners wanted to take the business in different directions, one domestic and the other focussing on international assignments
  • Separating a multi-million pound property portfolio between the shareholder families, so that one could concentrate on the rental business and the other could move into development
  • Breaking up a retail group to allow the owner to develop the different businesses in different ways, depending on the local market for his products.

Whither Partnerships?

There has been a huge amount of publicity about HMRC’s attack on partnerships in this year’s Budget, but the biggest question is what to do about the inevitable changes?

The first major change treats certain members of LLPs (limited liability partnerships) as employees, with major tax and cash-flow consequences. This will apply to ‘partners’ who have fixed income, or income that isn’t partly based on the partnership’s profits, who do not have significant influence and whose partnership fixed capital is insufficient. If you have clients that have partners who fail all 3 of these conditions, we can help you resolve the problems so that the impact of the new legislation is minimised.

The other change affects ALL partnerships that have mixed memberships of individuals and non-individuals. Usually, this means corporate members, although the new rules apply to trusts and other non-individuals in partnership, and the rules may apply to partnerships with only corporate partners, too. If there is no commercial reason for allocating profits to the company partner, HMRC can treat those profits as belonging to the individual, who will then have to pay income tax at up to 45% and Class 4 NICs on the profits, instead of the company only paying 20% corporation tax. We have a great deal of experience helping people decide how best to deal with these changes and how to unwind the structures efficiently, if that’s appropriate.

The new rules have applied since 6th April 2014, so you may need to act quickly!

Call or email Pete right away.

 

EFRBS Settlement Offer

HMRC has started an initiative to settle outstanding EFRBS cases, by issuing an EFRBS Settlement Offer under the Litigation and Settlement Strategy.  Further details of the offer can be found on HMRC’s website, here.  Your clients may well have received an offer letter from HMRC, and the obvious question is whether to settle.  HMRC’s letter requires an expression of interest by 31 December and for the settlement to be completed by 30 June 2014, so the timescale for making a decision is very short.  That said, we do not believe that an expression of interest is binding on your clients.  So if they decide not to settle as the discussions with HMRC proceed, they can withdraw from the initiative.

There are two alternative offers: one is to settle on the basis that no CT deduction is due, so that the CT is paid on the contribution and the professional fees; the other is to pay the income tax and NICs in respect of the contributions to the EFRBS, in which case a full CT deduction is given for the contributions to the EFRBS and for the professional fees.  Both have their advantages and disadvantages.

 

Settlement for CT only

The first version is not at all generous, as, in effect, HMRC want you to revert to the way they see the legislation, so that the CT deduction is not due until someone pays income tax and NICs on the amounts contributed.  This means that HMRC will not then press for the income tax and NICs until amounts are formally paid out of the trusts to the beneficiaries.  HMRC also say that they will disallow the deduction for professional fees incurred in setting up the EFRBS.  But we cannot see that this is justified under the normal corporation tax rules, as setting up an EFRBS is a business expense incurred wholly and exclusively for the purposes of the trade, and the legislation does not specifically disallow these costs, only the contributions.

If your clients are keen to settle, this is arguably a low-cost option, as the CT is a smaller amount than income tax and NICs.  On the other hand, it still leaves the trust in place and the trustees will need to operate PAYE / NICs as and when any payments are made out of the trust to employees or former employees.  That said, it might be possible for sums to be paid out of the trusts in future with lower tax charges.  For example, if the fund were to be used to pay pensions to the employees or directors when they retire, the rates of income tax may be lower or the pensioners might have retired abroad, so that there is no PAYE or NICs charge in the UK (the pensioner would, of course, have to consider whether there are any tax charges in their country or territory of residence).

 

Income tax and NICs settlement

This offer is on the basis of treating the contributions to the EFRBS as being earnings, subject to PAYE and NICs at the time the contributions were made.  The contributions, the income tax and NICs and the professional fees, would all then be deductible for CT purposes (there is no CT deduction for interest paid on settlement).  The settlement of income tax and NICs would inevitably involve larger numbers than a settlement for CT only but the idea is to clear the whole thing up and allow you to unwind the trusts by distributing the trust funds to beneficiaries post-settlement free of any further tax (save for any tax on overseas income in offshore EFRBS).

Our concern with this approach is that HMRC has had numerous attempts at persuading the Courts that contributions to EBTs should be taxed as earnings, and the Courts have rejected the argument every time.  So it seems likely that HMRC would be reluctant to litigate on this basis and would prefer to litigate cases on the basis of refusing the CT deduction, instead.

On the other hand, although such a settlement might lack a statutory basis, it can provide finality and closure for all concerned, which might be something your clients want.

If the company pays the income tax and NICs, these should be repaid to the company by the trustees or the employees (the exact requirements will depend on the wording of the trust Deed).  Otherwise, the income tax and NICs are treated as additional ‘earnings’ of the employee, so that more tax and NICs would be due.  We understand that HMRC has been quite helpful in this area, when considering settling EBT cases.

 

Other thoughts

There are a number of entirely legitimate uses of the funds in an EBT that do not or may not carry a charge to tax or, a lower ‘effective rate’ of tax.  As mentioned, paying out pensions might be an efficient way of using the funds, either through lower tax rates in the future or because the individuals concerned are no longer UK resident.  Other thoughts include selling assets to the trust, licensing assets through the trust, etc. We would be happy to discuss these in more depth, if they might be of interest to your clients.

 

Conclusions 

While neither route to settlement is entirely satisfactory, both have their potential upsides, including getting HMRC to go away.  That said, if your clients are comfortable with their current position, they could arguably be no worse off settling later, with the only downside being a greater charge to interest. However, there could be an increased risk of incurring tax charges on additional earnings if the trustees do not reimburse the company for any income tax and NICs which are subsequently held to be due on the contributions and which are paid outside the EFRBS Settlement Initiative.

To a very large extent, it comes down to how your clients feel, whether they want closure or partial closure, whether they are prepared to wait and see, and so on.  While HMRC suggest that they will litigate every case that doesn’t offer to settle, we don’t believe that they can litigate every single case, so they will have to use the lead case procedure, which may allow others to adopt a wait-and-see approach.

The Tax Aspects of Corporate Restructuring – Pitfalls & Challenges Explained

The taxation of corporate transactions is complex but, if properly understood, can ensure that commercial transactions are not encumbered by unwarranted tax liabilities.

This half-day seminar will take you through the tax rules which govern company reorganisations, mergers and demergers and other forms of corporate and group reconstructions and demonstrate how they work in practical situations.

Find out more and book your place >

We’re exhibiting at the Leicester Business Event 2013 (LBE13)

RCI0001EWe’re exhibiting at the Leicester Business Event 2013 (LBE13) on 3rd October at the Leicester Tigers GNC stand from 9.30am until 4.30pm. Come and see us at the (FSB) Federation of Small Businesses stand.

Exhibition spaces are now fully booked for the Leicester Business Event 2013 (LBE13) however visitors can attend the event for free with the opportunity to explore over 110 exhibition stands which are spread across two floors.

Visitors are encouraged to pre-register to attend the event for their pre-registration pack which includes a full list of exhibitors, floor plan, event schedule and name badge. This will save queuing on the day and give visitors the opportunity to prepare their own strategy for making the most of the event for their business or organisation.

Not only does the event have a variety of exhibitors but also, for the first time, the exhibition is featuring a section called the Market Street which will be located on the ground floor known as the Final Whistle and will have high street retailers with products to sell on the day.

Other activities will be held throughout the day including seminars with eight speakers, two speed networking sessions with the opportunity to meet 18 different businesses in under an hour. There’s also a ‘Meet the Buyer’ session where you can have a one-to-one consultation with a variety of public sector suppliers and larger organisations.

Free to attend, the exhibition is going to be the biggest it has ever been with an expected 1,000 visitors.

To register and receive your free pre-registration pack and badge, please visit http://www.hi2events.co.uk/pages/events/eventitem/LeicestershireBusinessEvent2013LBE/86/.

For a full list of exhibitors please visit http://www.leicesterbusinessevents.co.uk/Exhibitors.aspx

Substantial Shareholdings Exemption

The substantial shareholdings exemption was introduced in 2002. The rules effectively allow trading companies and groups to sell shareholdings in other trading companies and groups without suffering a charge to corporation tax on chargeable gains.

The legislation is complex and detailed, and this half-day seminar will take you through the rules, from the basics to more advanced areas, and give both technical insights and practical advice on their application of the rules for your corporate clients.

Find out more and book your place >

Corporate Intangibles: Technical Insights & Practical Advice

The corporation tax rules for intangibles assets, including goodwill and intellectual property, were introduced in 2002 and rewritten in 2009 into Part 8 CTA 2009. The rules effectively apply accounting treatment for tax purposes, except for the plethora of exceptions to this general rule!

This half-day workshop will take you through the legislation, from the basics to more advanced areas, and give both technical insights and practical advice on the application of the rules to your corporate clients.

Find out more and book your place > 

The Tax Aspects of Corporate Restructuring – Pitfalls & Challenges Explained

The taxation of corporate transactions is complex but, if properly understood, can ensure that commercial transactions are not encumbered by unwarranted tax liabilities.

This half-day seminar will take you through the tax rules which govern company reorganisations, mergers and demergers and other forms of corporate and group reconstructions and demonstrate how they work in practical situations.

Find out more and book your place >