The following Owner-Managed Businesses guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
The guidance below contains specific comments on clearance applications as they refer to non-statutory and statutory demergers, and should be read in conjunction with the general guidance on drafting clearance applications in the Drafting clearance applications guidance note.
A non statutory demerger may involve several steps in order to achieve the desired result. These will differ depending on the circumstances but typically will require clearance under the following provisions:
TCGA 1992, s 139 (reconstruction relief for corporate capital gains)
TCGA 1992, s 138 (reconstruction relief from capital gains tax for shareholders under
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There are several sets of provisions in the Taxes Acts which relate to ‘close’ companies, most of which are anti-avoidance measures aiming to catch transactions between those companies affected and their owners, where there may otherwise be a tax advantage. Broadly speaking, most owner-managed or
This guidance note explains the general rules surrounding the availability of indexation allowance on the disposal of company assets and provides information on the rebasing rules for assets held on 31 March 1982. For an overview of the general position regarding company disposals, please refer to
Maintenance payments are payments made by a taxpayer to their former or separated spouse for the maintenance of that former spouse or their children. To obtain any tax relief for maintenance payments, one of the couple must have been born before 5 April 1935 and the payments must be made by virtue
The corporate interest restriction (CIR) essentially limits the amount of interest expense a company can deduct from its taxable profits if the interest expense is over £2 million. The actual mechanics of the CIR calculation are highly complex (the legislation is over 150 pages long) and are
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