HMRC Put a Spotlight on Phoenixing HMRC have published their new spotlight (47) expressing their discontent with schemes that seek to bypass the targeted anti-avoidance legislation commonly referred to as the ‘phoenixing provisions’. Those who have participated in such schemes should be cautious of challenge by HMRC, particularly in light 
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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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The Enterprise Investment Scheme has proved a valuable tax relief both for those entitled to the relief on their investment and the improved attractiveness afforded to qualifying companies in generating equity investments. The EIS forms part of a number of tax relieved schemes under the heading of venture capitalism. Other 
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The Taxation of Cryptocurrency & Tax Efficient Cryptocurrency. One Year On… The cryptocurrency boom of autumn 2017 saw an explosion of interest in cryptocurrencies, blockchain and related technologies and has even resulted in the emergence of “crypto-millionaires”. Many financial advisers have been left scratching their heads as they turn to 
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Dividend Planning – Dividend Waivers Here at Enterprise Tax we work with a number of Owner Managed Businesses (“OMBs”) and Small-Medium Sized Enterprises (“SMEs”). More recently there has been a surge in individuals who historically entered into schemes designed to extract the fruits of their labour whilst attempting to bypass 
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A new principles-based test has been introduced by the Finance Act 2018 which imposes a ‘risk-to-capital’ gateway condition. The condition is designed to ensure that the schemes focus investment in companies with genuine intentions for long-term growth and development, as opposed to companies which exploit the schemes by participating in 
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SDLT tax avoidance: Taxpayer left feeling the blues Overview Project Blue Ltd v HMRC – a representative case for sub-sale avoidance schemes – has been decided in favour of HMRC. The case involved Project Blue Ltd which acquired land from the Ministry of Defence for consideration of £959m and utilising 
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HMRC have updated their CGT manuals providing an update to their understanding of cryptocurrency and block-chain technology, with clarity in determining how capital gains from cryptocurrency are computed and the tax position of “hard-forks”. Following the cryptocurrency boom at the back end of 2017 which saw a surge in the 
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If you’re looking to give employees shares in your company, beware the tax implications! I encounter many entrepreneurs who wish to recognise the efforts of their early-stage employees in creating a successful venture by considering giving them a share of their business. Those entrepreneurs who are comfortable giving their employees shares 
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R&D: Research, Relief & a Lack of Awareness In recent years, Britain has become fertile ground for those with an entrepreneurial spirit. Last year, in fact, the number of new companies formed was a new record with more than 650,000 businesses set up. A considerable proportion of those are relatively small 
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