The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
This guidance note 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.
For overall guidance on demergers, including choice of the most appropriate route and planning the demerger project, see the Demergers ― overview 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
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Summary of capital allowances on carsThe current capital allowance rates applicable to cars are as follows:Pool typeDescription of carRateLegislationMain rate poolNew and unused cars with CO2 emissions over 50g/km but not more than 110g/km (to be reduced to 50g/km and below from April 2021)18%CAA
IntroductionUK resident individuals who are non-UK domiciled can benefit from the remittance basis of taxation. The remittance basis allows for relief from UK taxation for non-UK sources of income which are not brought in (or remitted) to the UK. A remittance is any money or other property which is,
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