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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No safe havens 2019 – offshore compliance matters

Since 2010, HMRC have raised an additional £2.9 billion through its focus on offshore non-compliance, through initiatives including 6 separate disclosure facilities, a deal with Switzerland and the introduction of a series of legislative measures,...

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Capital allowances for new non-residential structures and buildings

In the Autumn 2018 Budget, the government introduced a new capital allowance for new non-residential structures and buildings. The government has welcomed comments up until 24 April 2019.  An overall response to consultation responses will be...

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Update to HMRC’s ‘Tackling tax avoidance, evasion, and other forms of non-compliance’ policy document

A number of anti-avoidance measures including anti-fragmentation rules and changes to Controlled Foreign Company rules were announced in the Budget 2018 to be enshrined in legislation in the Finance Act 2019. The ‘Tackling tax avoidance, evasion,...

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Changes to Entrepreneurs’ Relief: Impact on Growth Shares

In the Autumn Statement, the Chancellor announced important changes to the tests to qualify for Entrepreneurs’ Relief (‘ER’).  These changes have the potential to have a significant impact on the employees who have received employee...

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