Tax Aware

Tax Aware

Issue 4
Family investment companies: an alternative approach to succession planning

Family investment companies: an alternative approach to succession planning

Despite trusts being the traditional wealth and succession planning preference, family investment company ("FIC") structures are being increasingly used by individuals as an alternative. We are seeing this trend grow due to the UK's low corporate tax rates and the level of control family members can retain over assets owned by a company.

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A digital tax for a digital economy?

A digital tax for a digital economy?

Digitalisation affects all businesses to varying degrees. Smart contracts, high speed broadband, digital networking… as the 'digital economy' provides ever-evolving ways of doing business, countries are increasingly seeking ways to tax non-resident companies that derive revenue from within their borders. Governments are in the process of consulting on changes to tax law at a national, European and global level, changes which could include unilateral digital taxes in the absence of a multilateral approach.

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Non-UK companies dealing in UK property to become subject to corporation tax

Non-UK companies dealing in UK property to become subject to corporation tax

From April 2020, non-UK resident companies that carry on a UK property business or have other income and gains derived from UK property will become chargeable to UK corporation tax.

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Two-nil win for Tottenham Hotspur

Two-nil win for Tottenham Hotspur

The Upper Tribunal has rejected an appeal from HMRC in a case relating to the taxation of termination payments made to football player employees of Tottenham Hotspur Limited.

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Accelerated Payment Notices: how might it impact upon you?

HMRC challenges claims for ATED/SDLT relief

The Annual Tax on Enveloped Dwellings (ATED) was introduced by the Finance Act 2013 and imposes an annual charge on corporate entities holding UK residential property worth more than £500,000. A penal fixed rate of 15% Stamp Duty Land Tax (SDLT) can also apply on the acquisition of UK residential property by a corporate entity. Relief is available for corporate entities running a "qualifying rental business", however we have seen a number of cases where HMRC has sought to deny taxpayers relief for loss-making rental businesses.

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Option to tax judged to be OTT

Option to tax judged to be OTT

The VAT rules providing that an option to tax (or VAT election) may be disapplied in certain circumstances have been around since 1997 but until recently there has been little case law providing guidance on how they should be interpreted. Two recent cases are considered below.

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The final word on compound interest claims against HMRC?

The final word on compound interest claims against HMRC?

The Supreme Court has unanimously rejected a taxpayer's claim for compound interest on overpaid VAT in Littlewoods Ltd and others v HMRC [2017] UKSC 70. The case alone was worth £1.2 billion to Littlewoods but worth potentially over £17 billion to the Exchequer when considering the five thousand cases stayed pending its outcome.

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