Overseas Branch Or Subsidiary?

Overseas Branch Or Subsidiary?

One important area which is due to come up in the Advanced Tax exam is advising a company on setting up either an overseas branch or an overseas subsidiary. The branch would be an extension of the UK company and its profits would be subject to UK corporation tax at...
Tax Tip: Incorporation Relief

Tax Tip: Incorporation Relief

An area due to come up in the September 2022 Advanced Tax is incorporation relief. This defers the capital gain when a sole trader transfers the business to a limited company. Gains will only arise on chargeable assets such as land and buildings and goodwill. Assets...
CGT Groups

CGT Groups

A very popular area in the Advanced Tax exam which is due to be examined in September 2022 is CGT groups. For CGT groups, the direct shareholding must be at least 75% but the indirect only has to be 51%. Companies in the same group can transfer assets to group members...
Inheritance Tax & Main Residence

Inheritance Tax & Main Residence

The main asset which potentially creates an inheritance tax liability in an individual’s death estate is the main residence. If the main residence is left to a UK domiciled spouse in the death estate, it will be completely tax free and covered by the interspousal...
Are Cash Gifts Always Tax Free?

Are Cash Gifts Always Tax Free?

Usually, gifts of cash do not have any income tax implications if they are paid out of the donor’s income. However, as the following case law shows it is possible for gifts to be treated as disguised remuneration if an existing business relationship exists. With...