Corporate Tax News
13 October 2008
HMRC has issued a briefing on the deduction of tax at source for interest treated as a distribution.
13 October 2008
Following the Marks & Spencer Plc v David Halsey case legislation was introduced in the UK purporting to implement the ECJ's judgement.
02 October 2008
New PAYE regulations came into force on 6 April 2008 permitting HMRC to make a direction to transfer an outstanding PAYE liability from an employer to an employee.
11 September 2008
A closer look at HMRC guidance on salary sacrifice.
04 September 2008
A review of the recent case of British Association for Shooting and Conservation Limited (BASC) v Commissioners for HMRC.
13 August 2008
The case Johnston Publishing (North) Limited v Revenue and Customs Commissioners concerns de-grouping charges which bite where a group company has received an asset on a no gain-no loss basis from another group company and then leaves that group. The company leaving the group is charged to corporation tax on chargeable gains to the extent there would have been a charge levied on the transferor company.
11 August 2008
When an individual sells shares in a company he will expect to be taxed to capital gains tax on the proceeds received. Almost invariably this will be more beneficial than the proceeds being treated as an income receipt. For a higher rate taxpayer a capital receipt will be taxed at 18% with an annual exemption available whereas an income receipt will be taxed at 40%. However the recent cases of Lloyd v Revenue and Customs Commissioners and Snell v Revenue and Customs Commissioners highlight the danger that HMRC may use anti avoidance legislation to reclassify the receipt as an income receipt in certain circumstances.
06 August 2008
New Regulations have come into force to implement the changes to the VAT exemption for fund management services.
06 August 2008
In the case of Trustees of The Nelson Dance Family Settlement v HMRC (SpC 682) the Special Commissioner held that business property relief ("BPR") for inheritance tax purposes was available on transfers of value even where the transfer was not of the property itself (i.e. a business or an interest in a business) but simply reduced the value of that property.
30 June 2008
The recent Special Commissioners' case of Corbally-Stourton v HMRC, has added clarity to the law on HMRC's ability to raise a discovery assessment.
25 June 2008
The option to tax rules have been amended with effect from 1 June 2008