Substantial shareholding exemptions: unusual pitfalls
In the context of M&A transactions, the ability to benefit from the UK substantial shareholding exemption on gains d...
Large Corporate
Large Corporate
Group financing arrangements: tackling hybrid mismatches
One of the key targets of the G20 led Base Erosion and Profit Shifting project was multinational groups that exploited d...
Loss carry back rules: the case of Civic Environmental Systems
When writing this article, I was reminded of my article ‘What a carry back’ in the January 2020 issue of Tax Adviser....
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Rescuing a business from insolvency: gaining more time to pay your debts
There are several routes to rescue an insolvent company, but to give a business the best possible chance of recovery, se...
Customs duties and transfer pricing: can we bring these more in line?
Following updates to HMRC customs valuation guidance issued in late 2022, the interaction between transfer pricing and c...
The future for whistleblowing: speak up and stop harm
Rarely a day goes by without a whistleblowing story in the press – from patient safety concerns in hospitals, to fraud i...
UK imports and exports: the impact of Brexit
HMRC estimated that the number of businesses importing or exporting would rise from 250,000 prior to Brexit to 400,000 a...
Beneficial loans: the importance of getting your timing right
I can remember the first time that I came across an assessment in relation to a loan to a participator....
Combining employee ownership trusts with share schemes: a complicated compound
More and more is being written about employee ownership trusts and the tax incentives available when establishing them (...