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‘Bed and breakfasting’ was the pre-1998 practice of selling shares and repurchasing them the following day. This technique can still be used in a modified form to achieve capital gains tax (CGT) savings for current or future tax years using:•a spouse / civil partner•a self-invested pension plan
IntroductionThe CFC rules as outlined in this note apply to accounting periods beginning on or after 1 January 2013, the date upon which significant changes made by Finance Act 2012 became effective.From this date, the CFC rules also apply to foreign branches in respect of which an exemption
The reform of corporate losses within Finance (No 2) Act 2017 included a mixture of relaxations to the use of losses within the previous regime which applied before 1 April 2017 and also a major restriction (50% for most companies) on the amount of profits after 1 April 2017 that can be covered by
Current year relief and carry back lossesCurrent year relief for trading lossesTrading losses can be offset against total profits of the same period. Total profits covers, for example, chargeable gains or non-exempt dividends.The maximum claim for relief is the lower of the available loss or the