Much of the UK’s tax code relies on tests that refer to share capital. So it is important for tax practitioners to understand the company law issues involved and for corporate lawyers to understand what tax practitioners need. This half-day seminar will take you through many of the tax issues where share capital is relevant, giving you both technical grounding and practical advice.
What You Will Learn
- Broad overview of the tax tests
- 51%, 75% and 90% subsidiaries
- Ordinary share capital
- Non-ordinary share capital
- What is ‘control’ for tax purposes?
- Group relief
- What is group relief?
- How do the tests apply?
- Equity holders and ‘normal commercial loans’
- Opportunities and elephant traps?
- What is a company / non-UK entities
- Are they companies?
- Do they have share capital?
- Memec and Anson revisited
- Practical issues
- Capital gains
- Capital gains groups, SSE groups and comparisons with group relief groups
- The substantial shareholdings exemption
- Share exchanges
- Stamp duty
- Exemption for share exchanges
- Swamping mechanisms
- Reduction of capital mechanisms
- Stamp duty anti-avoidance
18th December 2019 – London 2:00pm – 5:15pm
To find out more and to book click here: