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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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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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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HMRC Enquires, Discovery Assessments & Closure Notices HMRC enquiries – background Each year, HMRC undertake checks to validate the information submitted on the more than 10 million self-assessment tax returns it receives. HMRC may select a random selection of returns for enquiry; however, HMRC have the right to open an 
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McLaren Racing Ltd v HMRC… The Tax Position on CTA 2009 s54; Fines, Penalties, Expenses & Business Profits Tax relief (or not) for fines Legislation (CTA 2009 s54) states that a company can deduct expenses that are wholly and exclusively for the purpose of the trade against their business profits. 
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Tax returns: HMRC clamps down on ‘careless’ city tax errors “To err”, wrote the English poet Alexander Pope, “is human”. Glancing over the latest HMRC annual report, which was published this July, one might add that it’s also hugely expensive. According to the Revenue’s figures, a £9.2 billion chunk of 
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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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