The following Owner-Managed Businesses guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.
Large companies and groups are (generally) entitled to research and development relief at 25%. Small and medium-sized enterprises are eligible for relief at a higher rate. Venture capital companies can be eligible for relief at the SME rate even if they are a member of a group, provided that they are autonomous: in very broad terms that they carry on investment activities which have commercial reality in their own right rather than support the activities of the wider group. This dispute was whether a member of a group of companies qualified in its own right as a venture capital company. This is ultimately a matter of fact and the detail may not be of wide interest, but all involved in advising on R and D tax credits will want to read paragraphs 92 onwards, particularly the discussion of the status of HMRC’s guidance in this area.
Interest incurred by a company is (at a very high level of generalisation) tax-deductible unless it was incurred for a tax avoidance purpose. Here, the group carried out an internal reorganisation after the acquisition of another large group of companies. As is so often the case, there were genuine commercial reasons to support what was done as part of a refinancing arrangement, but there was also no doubt that tax efficiency was a feature of the planning. The evidence was that it would enable relief for accumulated losses to be obtained immediately rather than over the estimated 25 years which would have been required without the restructuring. HMRC
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
The supply of fuel and power is treated as a supply of goods for VAT purposes. Supplies are fuel and power are normally liable to VAT at the standard rate. However, providing certain conditions are satisfied, it is possible for suppliers to charge the reduced rate of VAT on certain supplies of fuel
Statutory references to ITTOIA 2005 relate to unincorporated businesses and CTA 2009 relate to companies unless otherwise stated.Legal and other professional fees can represent substantial costs to a business. A detailed analysis is often required for the purpose of preparing tax computations as
Tax professionals will often be asked to provide input into the financial statement work undertaken by audit professionals. This guidance note is intended to give an overview of some of the key issues when undertaking audit work.This note is an introduction only and is written on the assumption that
Terminal loss relief for trade losses in the final 12 monthsTrading losses incurred by a company in the final 12 months leading up to the discontinuance of trade may be carried back for up to three years from the period beginning immediately before that 12-month period. So if the final accounting