CGT deduction for planning permission fees?

Business Asset Disposal Relief now carries an 18% rate. Understand the lifetime limit, qualifying conditions and the difference between sale proceeds and taxable gains....keep reading

How the rules from April 2026 affect family businesses and farms, including spouse transfers, AIM shares and the questions to ask before making gifts....keep reading

Moving to the UK or recently returned? Check eligibility, the cost of losing allowances and why the four-year window needs planning....keep reading

In this article we look at the UK tax implications for non-residents investing in UK property after the 2024 Budget....keep reading

In the 2024 Autumn Budget it was announced that Non Dom status will be replaced from April 2025 with a new residence-based Inpatriate Regime. We look at how this will operate based on the latest Finance Bill....keep reading

The 2024 Autumn Budget included significant inheritance tax changes to the availability of APR and BPR from April 6, 2026. In this article we look at the potential impact of these changes on trusts holding agricultural or business property....keep reading

In the 2024 UK Autumn Budget, the Chancellor announced changes to the inheritance tax with amendments to Agricultural Property Relief and Business Property Relief. In this article we look at the impact of the changes as well as simple planning strategies....keep reading

Moving to the UK requires consideration of a number of tax issues. One key issue is the treatment of any foreign incorporated companies that are owned or controlled. In this article we look at the key issues....keep reading

In this Practitioner Zone report we look at the tax treatment of land pooling arrangements, and some of the options to structure land pooling transactions tax efficiently....keep reading

Obtaining a UK domicile of choice can have a significant impact on an individuals UK tax treatment (including income tax, CGT and inheritance tax). In this article we look at how obtaining British citizenship can interact with this....keep reading

In this article we look at some of the factors to consider when choosing between a family trust or a family investment company....keep reading

In this Practitioner's article, we look at a recent case of the First Tier Tribunal on IHT 'Double Trust' planning....keep reading

In this Practitioner Zone report we look at the tax implications of a distribution in specie of UK residential property from an overseas company...keep reading

In this article, we look at some of the issues to be considered for long-term UK residents looking to avoid establishing a UK domicile of choice, including the impact of a recent case....keep reading

In many cases, the transferable nil rate band prevents the need to create a discretionary trust on the death of the first spouse. However, this is not always the case. In this article, we look at the role of discretionary trusts and deeds of variation in 2023 IHT Planning....keep reading

Following a request from one of our members we've looked in detail in this article at the UK tax implications of trusts migrating overseas. Trust migration essentially means that a UK resident trust becomes non UK resident....keep reading

One of the often forgotten implications of a transfer to an offshore company is that this is a chargeable lifetime transfer ('CLT') for inheritance tax purposes. In this Practitioner Zone article we look at how the 20% IHT charge on a CLT to an offshore company could be reduced...keep reading

Tax planning for holiday homes doesn't just require an analysis of the inheritance tax implications, but consideration should also be given to income tax, capital gains tax and stamp duty land tax. All of these can be relevant. In this practitioner zone article we look at the key tax planning options...keep reading

In this article we look at the tax issues to consider on corporate share deals including key tax exemptions, reliefs and considerations for a tax efficient disposal....keep reading

Gifts can be a highly effective strategy to minimise inheritance tax, however, the timing of gifts can have a significant impact on the amount of the IHT reduction. In this article we look at the timing of gifts for IHT purposes....keep reading

In this Practitioner Zone report we look at the IHT loss relief for shares and how beneficiaries can take advantage of this to reduce the IHT on shares....keep reading

Following a members tax question we've looked at the tax position of non resident partners. This article looks at how non UK resident partners are taxed in the UK and how they could structure their affairs to reduce UK tax...keep reading

In this Practitioner Zone report we look at the IHT position on gifts from life interest trusts....keep reading

When someone mentions a 'trust' the usual reaction is to think of a separate trust entity that has trustees and owns and manages assets on behalf of beneficiaries. However this is not necessarily the case. This article looks at the use of a bare trust and how it can be advantageous in tax terms, particularly for using children's annual exemptions....keep reading

On the death of a shareholder the question of whether the continuing shareholders have sufficient funds to buy the deceased's shares can be a significant issue. In many cases, a suitably-drafted cross-option agreement, backed by an appropriate term assurance policy is the solution. This can be drafted on a stand-alone basis or can be included as a separate section in a shareholders' agreement.In this Practitioner Zone article we look at this in more detail....keep reading

In this Practitioner Zone report we look at some simple strategies for using trusts in UK tax planning...keep reading

If you trade via a UK company, the general rule is that it would be subject to UK corporation tax even if the controlling directors or shareholders were non UK resident. However as a non resident individual you may be looking at options to reduce the UK corporation tax charge. In this article we look at the UK tax planning options...keep reading

In this Practitioner article we look at the use of Growth Shares to structure a tax efficient business exit....keep reading

One possibility to reduce tax on property trading is by using a trust. The general idea would be that you could save the 40% or 45% income tax charge you'd be subject to if you did the development in your own name by using a trust. The trust could be subject to income tax at the basic rate of 20%. There could therefore be a significant tax saving. Practitioner Zone report....keep reading

The reservation of benefit rules are a very common trap for families looking to transfer ownership of the family home. In this article we look at the scope and impact of the rules....keep reading

In this Practitioner Zone we look at making gifts to reduce your estate for IHT purposes out of surplus income...keep reading

Individuals moving to the UK who hold an interest in, or have other connections with a non-resident company should carefully consider the impact of their personal change in residence with the residence of the foreign company. In this article, we look at some of the key considerations....keep reading

In this members article we look at the changes to the CGT treatment of inter-spouse transfers from April 2023....keep reading

One of the key benefits of making gifts out of income is that they are not potentially exempt transfers for IHT purposes and therefore aren't subject to the 7 year survivorship period. In this article we look at the latest rules on when and how to make gifts out of income....keep reading

This article looks at some of the issues and potential pre-arrival tax planning opportunities for an individual moving to the UK....keep reading

In this article, we look at one of the key measures in the 2023 Spring Budget, to remove the Pension Lifetime Allowance....keep reading

In this article we look at some of the measures impacting on the tax treatment of real estate in the 2023 Spring Budget. |...keep reading

In this article, we look at some of the key business tax developments in this weeks Budget....keep reading

In this article we look at some of the key personal tax changes in yesterday's 2023 Spring Budget....keep reading

In this article we look at how family investment companies can be used to pass wealth on tax efficiently....keep reading

In this Practitioner Zone report we look at when and how to "bank" the inheritance tax reliefs to reduce IHT...keep reading

We looked in a previous article at the two main methods of how a UK company can 'migrate' from the UK. In this article we'll look in more detail at a migration by transferring the management & control of a company overseas....keep reading

In this article we look at pre and post-sale trust planning issues and opportunities....keep reading

In this Practitioner Zone report we look at how to set the level of charges between UK and offshore companies. We look at three key areas that are commonly recharged: management services, interest and transfers of IP or other products. We look each area and examine how to determine an arms length rate...keep reading

In this practitioner zone report we look at the extent to which trusts can be used to ringfence assets, including when they are (and aren't) effective....keep reading

Both family investment companies and trusts can be useful for inheritance tax planning. In this article we look at the different tax treatment of both entities and when they can be useful....keep reading

In this article we look at how to make a gift correctly for IHT purposes. If the proper procedure isn't followed the gift can be ineffective for IHT, and the asset will simply remain in your estate...keep reading

Share buy backs are a common exit strategy when a founder or shareholder of a business wishes to leave. However, the tax treatment can be complex. In this article we look at the tax issues to facilitate a tax efficient exit....keep reading

If you're considering gifting overseas cash to family members you should ensure that you carefully consider the UK tax implications. In this article we look at the income tax and inheritance implications for both UK domiciliaries and non UK domiciliaries...keep reading

In this article we look at the options for structuring a personal injury trust....keep reading

In this practitioner zone report we look at the tax treatment of a UK resident individual receiving dividend income from India, including the impact of the UK-India double tax treaty...keep reading

The CGT annual exemption for individuals reduces from £12,300 to £6,000 from 6 April 2023, and to £3,000 from 6 April 2024. In this article we look at the options available....keep reading

In this Practitioner Zone report, we look at the interaction between UK and Swiss inheritance tax for individuals who are UK resident/domiciled with Swiss property and Swiss residents with UK property, including the impact of the UK-Switzerland estate tax treaty...keep reading

In this Practitioner Zone report we look at the tax residence of foreign trust companies including relevant procedures and actions to have in place to ensure the non residence status...keep reading

In this Practitioners article, we look at the key situations where a trust can still be beneficial, both for tax planning and other purposes....keep reading

We've looked in previous articles at exactly what constitutes a remittance of overseas income or capital gains. In this article we look in detail at exactly when and how taxable remittances are made using UK and overseas credit cards...keep reading

It's well known that there are specific anti avoidance rules than can tax parents on income arising to a child where they made the original transfer. In this article we look at the tax treatment of non doms who make transfers to minor children and how the anti avoidance rules will apply to them....keep reading

Without careful planning, in certain cases the 7-year rule for IHT potentially exempt transfers (PETs) can become the 14-year rule. In this article we look at when this can occur....keep reading

If you're a non dom and have been taxed on the remittance basis, determining the tax treatment of any remittance of proceeds from your foreign capital gains is crucial. In this article we look at the tax treatment of proceeds and capital gains under the remittance basis...keep reading

I have a Uk Ltd company and the majority of my travel and subsistence expenses are reimbursed by my major client in Italy. What is the best way to show these reimbursements in order to avoid they add up to my total turnover and increase my tax? Thks...keep reading

When planning for inheritance tax, any payouts under a life insurance policy can be included in your estate for inheritance tax purposes unless you arrange for the policy to be held in trust. This article looks at the tax implications of using a flexible gift trust or a bare trust to hold an insurance policy...keep reading

When considering your UK ties, what you must avoid at all costs, if you have been resident in any of the last three years, is to trip three of the sufficient ties tests. If you do, there is a special deeming rule whereby days of presence (and not only nights) will be counted. This article looks at this in detail...keep reading

In this article we look at the tax implications, opportunities and pitfalls of a gift and leaseback arrangement for the family home....keep reading

If you buy and sell any form of financial asset the chances are you'll be taxed as an investor.However, there is another classification that some can consider - this is being taxed as a trader. This article looks at the implications of the different status for financial traders and UK tax planning opportunities...keep reading

In this Practitioner Zone report we look at a recent case that looked at the tax treatment of dividends declared but not paid....keep reading

Land pooling (where 2 parties separately own land and agree to pool the land, usually to obtain planning permission and sell at a significant profit) can be complex, particularly in terms of the tax treatment. In this article we look at some of the tax structuring options...keep reading

In this article we take a look at recent cases and their impact on the tax residence position of trustees....keep reading

LLPs are required to annually re-test whether their members are employees or self-employed. In this article we look at the tests to be applied....keep reading

If you're looking at providing services from abroad to customers in the UK, it would be beneficial to pay careful attention to the terms of any double tax treaty. In this article we look at how using double tax treaties can significantly reduce your UK tax liability...keep reading

Working internationally (whether that is on a foreign secondment or simply being based in a different jurisdiction to your employer) can give rise to a number of UK tax issues. In this article, we look at the key tax issues and suggested measures....keep reading

In this article, we look at a recent case that looked at when an interim dividend was treated as paid for tax purposes....keep reading

Unlike individuals, companies are subject to an exit charge on becoming non UK resident. This applies where a company ceases to be resident in the UK and the broad effect of it applying is to ensure that any assets owned by the company are treated as being sold and immediately reacquired. This will then crystallise a charge to corporation tax on the capital gain that arises in the company. This article looks at the application of the exit charge provisions and how they can be mitigated....keep reading

Holding companies are often used as a form of financial funnel. By having a company located in a suitable holding company jurisdiction hold the shares in a variety of companies, it's possible to ensure that the profits are funnelled into a low tax, or tax advantageous environment....keep reading

In this article we look at the treatment of bonus payments made to members of an LLP. Determining the nature of the payment and whether the payment is made to an employee is a key consideration as employers NIC is levied on the payment if it is made in an employer-employee relationship....keep reading

As remote working is becoming more and more popular we thought we'd look at how a tax treaty would impact on someone working on the tax position for someone operating remotely....keep reading

We've received a number of questions recently relating to the tax position of gifts of income or capital from non resident/non doms. In this article we look at when such gifts can be subject to UK tax....keep reading

Following a request from one of our Practitioner members, in this Practitioner report we look at the UK tax treatment of payments to directors, including non-executive directors where additional services are provided...keep reading

In this members article we look at the current state of play in the taxation of crypto assets for UK resident individuals, including the tax planning issues and opportunities available....keep reading

In this article we look at the recent Court of Appeal decision that held that business asset disposal relief (Entrepreneurs Relief at the time) was available as the qualifying period to hold shares before disposal did not apply to trusts....keep reading

For CGT purposes, determining the period of ownership where there is an off-plan property purchase (and therefore the amount of PPR relief) can be complex.  In this article we look at the key principles based on case-law....keep reading

In this book we look at a variety of tax planning strategies that arise from the terms of the UK's double tax treaties. This book is updated for the 2022 changes....keep reading

Last week, John Swinney delivered the Scottish Government Budget for 2023/24. In this article we look at some of the key highlights....keep reading

In this Practitioner Zone report we look at a recent decision of the first tier tribunal that looked at the treatment of interim dividends and what this means for taxpayers....keep reading

For many people the family home is the most valuable asset they have. As such protecting its value will be of key importance. In this tax guide we look at the key tax planning opportunities for the family home and private residences....keep reading

This brand new (December 2022) edition of our best selling offshore tax planning book tells you what you need to know to take advantage of offshore opportunities and slash your UK tax bill. It's a pretty comprehensive look at plenty of UK and offshore tax planning techniques including residence, domicile, emigration, using offshore companies and trusts, buying property overseas and much more....keep reading

Inheritance tax is a particularly nasty tax as it's a tax on your capital that you've accumulated from your after tax earnings. In this book we look at some of the top ways you can legally reduce your inheritance tax liability....keep reading

The R&D tax credit regime is highly attractive and can currently provide a tax credit of around 33% of the expenditure paid. However, there are some significant changes to the regime from April 2023....keep reading

In this article we look at a recent decision of the first-tier tribunal that held that payments under an indemnity are not a remittance....keep reading

In this Practitioner Zone article, we look at the tax implications of the Autumn Statement for entrepreneurs....keep reading

In this article, we look at the latest decision of the first-tier tribunal on mixed use property for SDLT purposes....keep reading

The Autumn Statement included a number of key tax changes from April 2023. With the end of the tax year fast approaching we've put together a tax checklist to maximise tax efficiency before the 2023 tax changes come into effect....keep reading

This book looks at a number of tax planning issues for company owners and considers both corporate and personal tax planning opportunities available. It is updated for the latest changes for 2022/2023....keep reading

In this Practitioner Zone report we look at a recent case on the determination of capital gains on a foreign property....keep reading

Scottish tenants could obtain a refund of some of the land & buildings transaction tax (LBTT) paid when a lease is ended. We look at when and how this can occur in this article....keep reading

Determining tax residence status for the 2021/2022 tax year requires a consideration of the statutory residence test. HMRC have issued specific clarifications for determining residence status for the 2021/2022 tax year....keep reading

In this article we take a look at how a recent court decision impacts on the tax deductibility of deal fees....keep reading

In this article we look at the Patent Box scheme and how small & medium sized companies can use this to reduce their corporation tax rate to 10% on qualifying profits....keep reading

Buy-To-Let ("BTL") landlords have to consider Income Tax, Capital Gains Tax, Inheritance Tax and Stamp Duty Land Tax on their property holdings. In this book we look at tax planning techniques that all BTL landlords can consider to reduce the amount of these taxes they pay....keep reading

The measures announced in last week's Autumn Statement will increase the 60% effective tax rate. In this article we look at why....keep reading