Capital gains

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Practice notes
FORTHCOMING CHANGE relating to SDLT for non-residents buying residential property: As announced at Budget 2018, confirmed at Spring Budget 2020 and...
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23rd Oct
Practice notes
Once is has been determined that there is a notifiable transaction for SDLT purposes, it should be considered whether any reliefs or exemptions are...
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21st Oct
Practice notes
The sale of a 'business' is really a sale of assets bundled together. VAT would therefore be charged on the transfer of each asset in accordance with...
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Produced in partnership with Cathya Djanogly 8th Oct
Practice notes
Provisions in the Finance (No 2) Act 2017 (F(No 2)A 2017) made considerable reforms to the rules governing what companies can do with carried-forward...
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26th Sep
Practice notes
FORTHCOMING CHANGE: HMRC is consulting on changes to the hybrid mismatch rules to ensure that they work proportionately and as intended. Amendments...
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26th Sep
Practice notes
This Practice Note considers the steps to take in relation to SDLT once it is established there is a chargeable transaction. For details about the...
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26th Sep
Practice notes
Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to the gains and losses of intangible...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 26th Sep
Practice notes
FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: The government is asking for views on the principles and design...
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26th Sep
Practice notes
This Practice Note is about the issues that arise on a transfer of a going concern involving land and buildings.A transfer of a going concern (TOGC)...
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26th Sep
Practice notes
The substantial shareholdings exemption (SSE) is an exemption from corporation tax on chargeable gains for certain share disposals by companies. The...
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26th Sep
Practice notes
BackgroundOn 6 July 2018, the government published draft legislation to be included in Finance Bill 2019 (formally the Finance (No 3) Bill 2017–19,...
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26th Sep
Practice notes
Stamp duty land tax (SDLT) is charged on chargeable land transactions. Consequently, the concept of a land transaction and what this encompasses is...
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25th Sep
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–2021 will contain two technical amendments to the CIR rules to ensure the regime works as intended. The first is...
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25th Sep
Practice notes
If an exemption from stamp duty applies, a document (ie an instrument of transfer) which would otherwise be subject to UK stamp duty is exempt from...
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25th Sep
Practice notes
Unless an exemption or relief applies, payments of:•yearly interest (or amounts that are treated by tax legislation as payments of yearly interest),...
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25th Sep
Practice notes
The amount of stamp duty land tax (SDLT) payable on a chargeable transaction is determined by reference to the 'chargeable consideration' for the...
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25th Sep

Most recent Capital gains content

Practice notes
For a taxable capital gain to arise, there has to be a disposal, or a deemed disposal, of an asset. The taxpayer will need to establish when the...
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25th Sep
Practice notes
FORTHCOMING CHANGE: As originally announced at Budget 2018, the government ran a consultation between 1 April and 1 June 2019 on proposals to curtail...
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25th Sep
Practice notes
The way consideration payable for the acquisition of shares is structured is not always straightforward. In many cases payment can be delayed,...
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25th Sep
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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25th Sep
Practice notes
The conversion of a company's securities should be treated as a tax neutral reorganisation. The conversion is treated as not involving any disposal of...
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25th Sep
Practice notes
This Practice Note is about roll-over relief for capital assets, which is a deferral of capital gains tax, or corporation tax on chargeable gains, for...
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25th Sep
Practice notes
This Practice Note sets out how the capital allowances rules interact with the rules relating to:•capital gains tax, including corporation tax on...
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25th Sep
Practice notes
The capital gains degrouping rules apply where, broadly speaking, a company leaves a group holding an asset that was transferred to it by...
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25th Sep
Practice notes
This Practice Note is about the tax anti-avoidance rules that apply to a share for share (or share for loan note) exchange or a scheme of...
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25th Sep
Practice notes
Companies that are members of the same capital gains group may transfer assets between themselves free of corporation tax on chargeable gains (CGT),...
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25th Sep
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The annual tax on enveloped dwellings (ATED) was introduced in Finance Act 2013...
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26th Sep
Practice notes
ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons...
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26th Sep
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The value shifting rules are anti-avoidance provisions. They are similar to the...
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26th Sep
Practice notes
CORONAVIRUS (COVID-19): CIOT has asked the government to consider delaying changes to principal private residence relief (PPR) (which are due to take...
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26th Sep
Practice notes
BackgroundOn 6 July 2018, the government published draft legislation to be included in Finance Bill 2019 (formally the Finance (No 3) Bill 2017–19,...
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26th Sep
Precedents
HM Revenue and Customs[insert address][insert date]Election under section 171A(4) of the Taxation of Chargeable Gains Act 1992This election is made...
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26th Sep
Practice notes
The rules dealing with depreciatory transactions and dividend stripping are anti-avoidance provisions.They target the artificial transfer of value out...
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26th Sep
Practice notes
The capital gains legislation makes it possible for groups of companies to arrange to set allowable losses arising in one member of the group against...
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26th Sep
Practice notes
When a sole trader (or an individual running a business as a partner in a partnership) decides to incorporate that business, he transfers the assets...
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26th Sep
Practice notes
The way consideration payable for the acquisition of shares is structured is not always straightforward. In many cases payment can be delayed,...
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26th Sep

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