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Share buybacks

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Tax weekly highlights—29 July 2021

Tax weekly highlights—29 July 2021

The following Tax news provides comprehensive and up to date legal information on Tax weekly highlights—29 July 2021

RTI was available information for the purposes of discovery (Loughrey v HMRC)

RTI was available information for the purposes of discovery (Loughrey v HMRC)

The following Private Client news provides comprehensive and up to date legal information on RTI was available information for the purposes of discovery (Loughrey v HMRC)

The tax implications of hybrid working arrangements

The tax implications of hybrid working arrangements

The following Employment news provides comprehensive and up to date legal information on The tax implications of hybrid working arrangements

Import agent not agent acting in its own name for VAT purposes (Scanwell Logistics (UK) Ltd v HMRC)

Import agent not agent acting in its own name for VAT purposes (Scanwell Logistics (UK) Ltd v HMRC)

The following Tax news provides comprehensive and up to date legal information on Import agent not agent acting in its own name for VAT purposes (Scanwell Logistics (UK) Ltd v HMRC)

Featured Tax content

VAT treatment of parking facilities

VAT treatment of parking facilities

VAT treatment of parking facilitiesThis Practice Note is about the VAT treatment of parking facilities.Why does this matter?Charges for parking are...

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are shown at Companies House as being issued. However, where the form requires the date the shares were acquired by the employee, a date has not been inserted. Does this invalidate the section 431 election?

Two employees have been issued shares and entered into a section 431 election respectively. The date of the signatures is the date the shares are...

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?

VAT—what is a transfer of a business as a going concern?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summary

Property authorised investment funds (PAIFs)—summaryThe regime for property authorised investment funds (PAIFs) was introduced in 2008.It created a...

Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes

SDLT—deeds of rectification

SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes

How employment income is taxed—non-cash earnings or benefits

How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes

What is an intangible fixed asset?

What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

EIS—deferred gain becomes chargeable to CGT

EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes

Corporation tax—connected persons

Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes

Commercial service charges—VAT implications

Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes

Offshore receipts in respect of intangible property (ORIP)

Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Precedents

Clause—tax gross up—commercial agreements

1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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19th May
Practice notes

The Budget and Finance Bill process

The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes

Capital reduction demergers

Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As

Corporate redomiciliation—can a non-UK company redomicile into the UK?

Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes

R&D capital allowances

R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes

Transfer of a trade under common ownership

Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May

Most recent Share buybacks content

Q&As

Does a share buyback attract stamp duty?

Does a share buyback attract stamp duty?Stamp duty is an ad valorem duty which applies to transfers of stock and marketable securities for...
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Produced in partnership with Mary Ashley of Old Square Tax Chambers 6th Jun
Q&As

If a company buys back shares from two shareholders where the consideration for each is under £1,000, but for both together is more than £1,000, are they treated as two buybacks so each can fall within the 'under £1,000' stamp duty exemption, or are they treated in aggregate?

If a company buys back shares from two shareholders where the consideration for each is under £1,000, but for both together is more than £1,000, are...
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Produced in partnership with Kate Habershon of Morgan Lewis 6th Jun
Q&As

What are the income and capital gains tax consequences for a shareholder in a UK listed company, when those shares are bought back by the company for the same price as they were subscribed for as part of a share buyback? Is the tax treatment different for a non-UK/EU resident shareholder?

What are the income and capital gains tax consequences for a shareholder in a UK listed company, when those shares are bought back by the company for...
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6th Jun
Q&As

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price (broadly speaking) to be taxed as a dividend distribution. Does the same position apply to the proceeds received by a UK shareholder on a buyback carried out by an overseas company?

On a share buyback carried out by a UK company, one would usually expect any proceeds received by a UK shareholder in excess of the subscription price...
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6th Jun
Q&As

When does a share buyback carried out by a limited company take effect?

When does a share buyback carried out by a limited company take effect?A private limited company will only buy back its own shares off-market pursuant...
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5th Jun
Practice notes

Tax consequences of share buybacks

Tax consequences of share buybacksA limited company may buy back shares that it has in issue, provided certain conditions set out in the Companies Act...
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5th Jun
Practice notes

Unquoted trading company share buybacks—capital treatment rules

Unquoted trading company share buybacks—capital treatment rulesOn a share buyback that is implemented by the company directly or through an...
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5th Jun
Practice notes

Share buybacks—calculating the distribution and repayment of capital elements

Share buybacks—calculating the distribution and repayment of capital elementsFrom a shareholder’s perspective, when a company buys back its own...
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5th Jun

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