How is “Issued Share Capital” measured for ER purposes?

In Hunt v HMRC [2019] UKFTT 0210 (TC), the first-tier tribunal, which was heard on 17 January 2019, considered whether Mr Hunt was eligible for of entrepreneurs’ relief (“ER”) on the proceeds from the sale of shares held in Foviance Group...

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Preference shares – when are they Ordinary Share Capital?

Whether shares to be disposed of are considered to be “ordinary share capital” (OSC) is important in determining the availability of entrepreneurs’ relief (ER),”. To qualify for ER, the company in which the shares are being disposed of...

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Autumn Budget 2018 – Stamp Duty on listed securities

Stamp Duty and Stamp Duty Reserve Tax (SDRT) are only levied on the value of the consideration given in a transaction subject to stamp tax. This means that the amount of Stamp Duty or SDRT payable can be unconnected with the value of the assets...

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Autumn Budget 2018 – Digital Services Tax

Governments have found it very hard to capture the economic activity of the digital economy within the existing tax system, with public disquiet about the apparent mis-match between the taxes collected from and revenues generated in the UK by the...

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Autumn Budget 2018 – Employment Allowance Restricted

Employment allowance was introduced in the 2013 Budget and allows employers to reduce their liability for secondary Class 1 National Insurance Contributions (‘Employer NIC’) by £3,000 per annum. From April 2020 an employer will only be...

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