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Our experience
Some of the topics on which we have helped are listed alphabetically below. Click on a letter to jump to the relevant topic.
a | b | c | d | e | f | g | h | i | j | k | l | m | n | o | p | q | r | s | t | u | v | w, x, y, z
a
Associated |
When are companies associated? What has to be attributed and what does not? What is a minimal controlling group? Are companies which are in partnership associated? When does association of companies matter and when can it safely be ignored? Are companies which are “associated” with each other also automatically “connected” with each other and vice versa? |
b
Benefits in kind |
What benefits are chargeable? What benefits are not chargeable? What type of National Insurance Contributions should you be considering? |
c
Capital |
What allowances are due? Can you claim for integral features in your building or energy efficient plant? What are Flat Conversion Allowances? |
Charities |
Charities may be liable to pay tax and VAT on income if arrangements are not carefully structured. What exemptions are available? Who gets them? When do you need to charge VAT? How does Gift Aid work and what are its pitfalls? For our outline guidance note click here. |
Civil Investigation |
Serious investigations may be referred to specialist CIF units – if so it has move up a gear and you may need more specialist assistance. |
Companies in administration |
Companies in administration or in liquidation are subject to special tax rules. Particular problems can arise in respect of utilisation of losses. When can ESC C16 be useful and when should it be avoided? |
Construction |
Are you up-to-date with the new CIS rules? Did you realise that HMRC scrutinises the tax compliance patterns of contractors on-line on a month by month basis? They can withdraw gross payment status at any time. |
d
Demergers |
Splitting businesses up brings its own potential charges but these can often be mitigated by using the exempt distribution legislation or the provisions of the Insolvency Act. We can advise on clearances, drafting and implementation. |
Divorce and |
What are the income tax, capital gains tax and inheritance tax implications of divorce and separation for each spouse? A “holistic” approach is essential if pitfalls are to be avoided. |
Double Taxation Agreements |
What are the implications of trading or investing in one country while being resident in another? The answer usually lies in the relevant Double Tax Conventions or in the availability of unilateral relief – but only if a claim is made. We can help you find you way through the DTC maze. |
e
EIS relief |
Does it stand for “Enterprise Investment Scheme” or “Extremely Ill-advised Shareholder”? Are you looking for Income Tax relief or only CGT deferral? Either way, the restrictions can sometimes make you wonder whether the relief is worthwhile: make sure a clawback doesn’t come back and bite you. |
Employee Share Incentives |
Where do you start? Approved or non-approved? Shares or options? Would a phantom scheme fit the bill? |
Entrepreneurs Relief |
What are the requirements? What are the surprising omissions? How much advance planning is necessary? |
Enquiries |
How do you reply to HMRC’s enquiry? Is it serious or low key? What do they really want to know? |
Expatriates in |
What tax reliefs are available to long- and short-term residents of the UK? What are the critical dates? |
Expatriates overseas |
Will you remain liable to UK taxes? Will you become liable to local taxes? Can you choose? |
g
Groups of companies |
What counts as a group for accounting, CT, SDLT or CGT purposes? What losses and expense count for group relief? How do groups affect capital gains? |
i
Incorporation of Businesses |
Should you incorporate? What can you incorporate? What are the costs? What are the reliefs? Is it a one-way street? |
Inheritance Tax Planning |
Are you happy for Mr Darling to get more than your own darlings or would you like to consider some straightforward steps that could be taken to reduce your liability to IHT? |
Intangible asset relief |
What is an “intangible asset” for tax purposes? What tax relief is available in writing off the cost of intangible assets? How are gains on intangible assets taxed? Familiar with the rules at Sch 29 FA 2002? |
International Tax |
You may need to consider transfer pricing: double tax conventions: thin capitalisation: controlled foreign companies: international VAT: taxation of expatriates and tax-protected remuneration: double taxation of profits: tax-efficient financing. Ask us. |
Investigations |
HMRC investigations should never be taken lightly and the wrong response can make it worse. It helps if you can read between the lines. And it helps if you are a former senior Inland Revenue inspector… |
IR35 |
Are you caught by the IR35 provisions? Has your business been accounting for tax and NIC correctly? Is the Revenue’s assertion as to your IR35 ststus correct? Are your contracts drafted in accordance to how you work? |
l
Limited Liability Partnerships |
How are LLPs taxed? In some circumstances creating an LLP can bring more tax benefits than incorporating a business. Have you considered corporate partnerships? |
Loan |
What’s within the scheme? What debits are allowance and what credits are taxable? |
Loans to participators |
Is the company close? What loans are caught? How much wider does the legislation extend? Are there ways round the tax charge? What’s the best way of clearing the indebtedness? |
m
Mergers |
Joining companies or businesses together is not as easy as it sounds but there are ways of mitigating the tax if you know how. |
n
National |
For prospective and existing employees; for the Self Employed; for those exposed to any combination of the various classes on National Insurance Contribution. Employers’ obligations, not necessarily only for payments to employees; Expenses and benefits that involve (sometimes) on payroll NIC deductions. |
p
P11D |
Are you doing them properly? Are you exposed to penalties for non-compliance? Need you be doing as many as you are? |
Partnerships |
How are changes in membership of a partnership affected by both income tax and capital gains tax rules? Can film partnerships still produce tax savings? What about UK tax and non- resident partners? Can Scottish partnerships be used in tax planning? |
PAYE |
What does PAYE encompass? How do you deal with various payroll and employee matters? |
Principal Private Residence Relief |
A person’s main residence is probably their most valuable asset. Whenever it is bought, sold or inherited HMRC will want a slice of that value by way of stamp duty land tax, capital gains tax, inheritance tax, and even, in some circumstances, income tax. Careful planning is always advisable. |
Property Taxation |
Which is it - property development or property investment? What is the most tax efficient way to hold property, in person or in a company? Does it matter where the property is located? Can UK tax be avoided by using offshore structures? |
r
Reconstructions and reorganisations |
Reorganisations usually involve disposals by shareholders and by companies. Income Tax, CGT SDLT and VAT can all raise their heads: but there are often ways through. Let us be your guide: we wrote the book! |
Research and Development Relief |
A hugely valuable reward for those companies which can negotiate the byzantine complexity of the legislation. |
Residence and Domicile |
The position was complex even before the 2008 changes; and our feeling is that the law and practice still has a way to go. There are still non-cost opportunities, particularly for the non-domiciled. |
Rollover Relief |
Most people have heard of the relief for replacement of business assets. But what exactly are the requirements? Far fewer have considered rollover relief for compulsory-purchase property or leasehold enfranchisement. We have. |
s
Sales and transfers |
What should you sell – assets or shares? How should the price be allocated? Any merit in pre-sale asset transfers or even incorporation? Or pre-sale share buyback or re-organisation? Should you leave the UK? Is a loan note option available? |
Schemes and stratagems |
Have you come across a marketed scheme and would like independent advice before recommending it? We have seen many variations on many structures and will usually be able to help you see the wood for the trees. |
Share buy-backs |
Will it be a capital or revenue buy-back? Can you choose? What are the conditions for each? What are the alternatives? |
Share Schemes and Options |
Where do you start? Approved or non-approved? Shares or options? Would a phantom scheme fit the bill? |
Share Valuation |
Whether for CGT, share schemes, IHT or some non-fiscal purpose we are able to help with company valuations. |
Special Civil Investigations work |
When a tax investigation is taken away from the local district things are getting serious and specialist support is usually appropriate. We have had many successful dealing with Enquiry Branch and its subsequent manifestations as SCO, SCI and CIF. Whether you want to hand the investigation over to us, retain us as consultants or simply bounce ideas: we’re here. |
Stamp Duty |
Much less of an issue than it used to be but not quite dead. We’re here to help. |
Stamp Duty Land Tax |
When is it due and on what value? When is market value relevant? Does anyone out there (HMRC included) understand the rationale behind partnership SDLT? |
Status enquiries |
If your business pays a freelancer, all well and good if there is a real Self Employed basis for the payment. Otherwise, if the person resembles an employee, your business is liable for the PAYE Tax and NIC deductions that you should have withheld. Interest and penalties as usual for getting it wrong. |
Substantial Shareholding Exemption |
Can any company benefit from the exemption? Is the exemption for companies only? What are the time limits for a claim? What is meant by “substantial”? |
t
Taper Relief |
Despite its abolition, claim to taper relief will remain a potential area of contention with HMRC for some years to come. |
Tax Warranties and Indemnities |
As part of due diligence on the purchase of a company the review of tax warranties and indemnities should always be carried by an experienced tax specialist. |
Transfer pricing |
Special rules require some businesses to substitute market value for some trans-border transactions. Are you within the rules? Is the transaction caught? If so, you must self-assess any transfer pricing adjustment or show that none is needed. We can help in assessing risk and in supporting valuations. |
Trusts |
Despite all the recent changes in tax treatment trusts still have a role to play in family financial planning. Do you need to talk through the options? |
w, x, y, z
Wills and intestacies |
Do you know that if you die without a will, at worst your estate could pass to the Crown? Even a simple will is better than nothing and often much more can be achieved with a little more sophistication. |
