The following Value Added Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
This guidance provides an overview of the topic of supply and consideration.
For detailed commentary on the legislation and case law on supply and consideration, see De Voil Indirect Tax Service Division V3.1.
A number of key issues arise in relation to supply and consideration from a VAT perspective. The table below sets out a number of the most important areas to consider, along with links to more detailed guidance:
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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
The substantial shareholding exemption (SSE) provides a complete exemption from the liability to corporation tax on the gains generated from qualifying disposals of shares and interests in shares by qualifying companies. Conversely, if losses are generated by the disposal and the SSE conditions are
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
This guidance note considers the capital gains tax implications where shares are sold in exchange for new shares.The consideration paid by a purchasing company to the shareholder(s) for their shares in a target company could be in the form of either:•new shares in the vendor in exchange for shares
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