Negligible Value Claims 2019 – The Facts The sale of company shares and other assets for more than their purchase price will generally give rise to a charge to capital gains tax. Conversely, the disposal of shares for less than their purchase price will result in a capital loss. Such 
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The Chancellor announced important changes to Entrepreneurs’ Relief in his 29 October 2018 Budget Statement. As discussed in a previous post, the changes as drafted had wide-ranging, and it is assumed untended, consequences. In particular, the new legislation as drafted could have denied Entrepreneurs’ Relief to any shares in companies 
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UK Budget 2018 – Tax Changes & Tax Planning for 2019 & Beyond. Despite speculation that the Chancellor would announce further restrictions to pensions tax relief, and fears that Entrepreneurs’ Relief might be scrapped, there were few surprises. More striking were the absences, with Brexit very much the elephant in 
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Have your cake and keep your half penny – do not forget Substantial Shareholder Exemption (SSE) I was discussing the benefits of Substantial Shareholder Exemption (SSE) with a client the other day and found myself using one of my Gran’s favourite expressions – “you want your cake and to keep 
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Budget 2018: Change in Definition of Permanent Establishment & Amendments to Diverted Profits Tax Change in Definition of Permanent Establishment If an overseas business has a UK Permanent Establishment (PE), the profits of the business that are attributable to that PE, either directly or indirectly, are chargeable to UK tax. 
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Transfer of a business to a Company (incorporation) – the tax issues Introduction Incorporation, or the transfer of a business to a Company, involves the transfer of an existing business to a new or existing company. This will generally take place at market value (though if a trading business one 
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Judicial Review and tax Introduction – Judicial review and tax The 2019 Loan Charge Action Group has launched a judicial review against HMRC in relation to the 2019 Loan Charge. In recent years, the courts have seen a sharp increase in judicial review against HMRC. In light of this, I 
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Tax avoidance: Tech, telly and Treasury tax tension Ever since the start of the Industrial Revolution in 18th-century Britain, entrepreneurs and politicians alike have recognised that technology sells. Across more than two centuries, from a mechanised textile industry to Twitter, innovation has transformed lives and swollen company bank balances. Unsurprisingly, 
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Badges of trade: is there are trading activity? Introduction – badges of trade Do not confuse the ‘badges of trade’ with the ‘badgers of trade’. Whilst the latter is an organisation of mercantile woodland creatures, the former is a set of key indicators that are used to determine whether a 
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Tax reliefs: killing tax’s sacred cows? Introduction As announced in the Summer, taxpayers are going to be asked to pay for a £20bn injection in to the NHS by 2023. Rumour has it that, where possible, this will take the form of a paring back of tax reliefs rather than 
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