When it comes to R&D Tax Relief, software development is one area which has historically been challenging for both companies and advisers. Identifying whether a project qualified for relief could be difficult. Whilst it is easy sometimes to overlook “the other side of the fence”, these types of claims also 
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‘taxing statutes draw their life-blood from real world transactions with real world economic effects’ In 1936, Lord Tomlin made the (now) infamous statement which gave tax payers a decisive advantage over HMRC. In effect, this was an approval for tax professionals to exercise their ingenuity in the pursuance of a 
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Social Investment Tax Relief: doing well and doing good Recognising the growing importance of “impact investment”, with investors seeking investments with social and environmental benefits as well as financial returns, Social Investment Tax Relief (SITR) offers valuable tax reliefs to investors to social enterprises. Social enterprises include charities, community interest 
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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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