The following article was written in July 2013 and discusses a case on incorporating a property r... more The following article was written in July 2013 and discusses a case on incorporating a property rental business. This is particularly relevant to the buy to let sector in the UK in the light of Government changes to the tax legislation, in order to discourage private landlords operating in this sector.
Investors' relief is a new CGT relief in the UK, which offers an attractive alternative to other ... more Investors' relief is a new CGT relief in the UK, which offers an attractive alternative to other types of tax advantaged schemes. This is a tax relief which should be of particular interest to business angels.
This paper discusses the forthcoming changes to the rules on entrepreneurs' relief and joint vent... more This paper discusses the forthcoming changes to the rules on entrepreneurs' relief and joint ventures, following the UK Budget for 2016. As we shall see, there are a few quirks to the new rules.
In this paper we shall look at the tax consequences when a landlord grants a short lease for a pr... more In this paper we shall look at the tax consequences when a landlord grants a short lease for a premium.
In this paper we explore how a corporate landlord is able to obtain tax relief for its finance co... more In this paper we explore how a corporate landlord is able to obtain tax relief for its finance costs.
In this paper we shall discuss new HMRC information powers which will affect a range of tax relie... more In this paper we shall discuss new HMRC information powers which will affect a range of tax reliefs available under various statutory schemes. In certain cases, failure to comply with the new rules may lead to a denial of the relevant tax break.
This is the fourth in our series of articles on venture capital trusts. In this article, we shall... more This is the fourth in our series of articles on venture capital trusts. In this article, we shall be exploring the conditions that describe what the portfolio looks like " on the outside " – the rules governing the type of investments that can be made. These rules are illustrated by looking at an Annual Report of a real live Venture Capital Trust.
This is the third paper in our series on Venture Capital Trusts where we look at the structural c... more This is the third paper in our series on Venture Capital Trusts where we look at the structural conditions applying to VCTs.
This is a short paper on year end tax planning. It explains how one can use options to delay a pr... more This is a short paper on year end tax planning. It explains how one can use options to delay a property sale for tax purposes, and therefore how to delay payment of capital gains tax for the seller.
This paper explores the recent changes to the corporate IP tax rules following the Autumn Stateme... more This paper explores the recent changes to the corporate IP tax rules following the Autumn Statement of 2015. Previously it was possible to bring IP within the corporate rules by transferring into a partnership vehicle. This is no longer possible as the paper explains.
This is a discussion of the case of Drilling Global Consultant LLP v HMRC, a case where a partner... more This is a discussion of the case of Drilling Global Consultant LLP v HMRC, a case where a partnership consisting of individuals and corporate partners was denied the annual investment allowance available under the capital allowances rules. This article was first published in Taxation Magazine.
This article is about the interaction between the EIS Scheme and Entrepreneurs' Relief. The latte... more This article is about the interaction between the EIS Scheme and Entrepreneurs' Relief. The latter is a relief whereby tax rates for a person selling his business can be reduce to 10%. It is now possible to defer paying the tax by reinvesting the proceeds in an EIS Scheme - but the legislation contains a small trap...
We have seen in previous articles how the degrouping rules operate to prevent the use of a corpor... more We have seen in previous articles how the degrouping rules operate to prevent the use of a corporate vehicle to shelter taxable gains. There are two sets of rules, one for capital assets and the other for intangibles (“IP”). In this article we shall look at how these rules differ, giving a specific example involving a business sale.
In this article, we shall discuss the degrouping rules as they apply to intangible assets , such ... more In this article, we shall discuss the degrouping rules as they apply to intangible assets , such as IP and goodwill (collectively referred to as IP). The tax treatment is similar to that applying to capital assets, but with important differences.
This is the third article in our series on corporate tax groups where we explore the rules govern... more This is the third article in our series on corporate tax groups where we explore the rules governing intra-group transactions, and how they are taxed. In this article we shall look at the rules relating to capital assets.
In this paper we shall look at the legislation and see how it ensures that (1) Intra-group transa... more In this paper we shall look at the legislation and see how it ensures that (1) Intra-group transactions are tax neutral, so that (2) The tax that would otherwise have been payable is collected only when the asset leaves the group.
This is the first of a series of articles on the taxation of corporate groups. The main theme of ... more This is the first of a series of articles on the taxation of corporate groups. The main theme of these articles is that intra-group transactions are tax neutral. The first article sets out what it means to be a group.
The following article was written in July 2013 and discusses a case on incorporating a property r... more The following article was written in July 2013 and discusses a case on incorporating a property rental business. This is particularly relevant to the buy to let sector in the UK in the light of Government changes to the tax legislation, in order to discourage private landlords operating in this sector.
Investors' relief is a new CGT relief in the UK, which offers an attractive alternative to other ... more Investors' relief is a new CGT relief in the UK, which offers an attractive alternative to other types of tax advantaged schemes. This is a tax relief which should be of particular interest to business angels.
This paper discusses the forthcoming changes to the rules on entrepreneurs' relief and joint vent... more This paper discusses the forthcoming changes to the rules on entrepreneurs' relief and joint ventures, following the UK Budget for 2016. As we shall see, there are a few quirks to the new rules.
In this paper we shall look at the tax consequences when a landlord grants a short lease for a pr... more In this paper we shall look at the tax consequences when a landlord grants a short lease for a premium.
In this paper we explore how a corporate landlord is able to obtain tax relief for its finance co... more In this paper we explore how a corporate landlord is able to obtain tax relief for its finance costs.
In this paper we shall discuss new HMRC information powers which will affect a range of tax relie... more In this paper we shall discuss new HMRC information powers which will affect a range of tax reliefs available under various statutory schemes. In certain cases, failure to comply with the new rules may lead to a denial of the relevant tax break.
This is the fourth in our series of articles on venture capital trusts. In this article, we shall... more This is the fourth in our series of articles on venture capital trusts. In this article, we shall be exploring the conditions that describe what the portfolio looks like " on the outside " – the rules governing the type of investments that can be made. These rules are illustrated by looking at an Annual Report of a real live Venture Capital Trust.
This is the third paper in our series on Venture Capital Trusts where we look at the structural c... more This is the third paper in our series on Venture Capital Trusts where we look at the structural conditions applying to VCTs.
This is a short paper on year end tax planning. It explains how one can use options to delay a pr... more This is a short paper on year end tax planning. It explains how one can use options to delay a property sale for tax purposes, and therefore how to delay payment of capital gains tax for the seller.
This paper explores the recent changes to the corporate IP tax rules following the Autumn Stateme... more This paper explores the recent changes to the corporate IP tax rules following the Autumn Statement of 2015. Previously it was possible to bring IP within the corporate rules by transferring into a partnership vehicle. This is no longer possible as the paper explains.
This is a discussion of the case of Drilling Global Consultant LLP v HMRC, a case where a partner... more This is a discussion of the case of Drilling Global Consultant LLP v HMRC, a case where a partnership consisting of individuals and corporate partners was denied the annual investment allowance available under the capital allowances rules. This article was first published in Taxation Magazine.
This article is about the interaction between the EIS Scheme and Entrepreneurs' Relief. The latte... more This article is about the interaction between the EIS Scheme and Entrepreneurs' Relief. The latter is a relief whereby tax rates for a person selling his business can be reduce to 10%. It is now possible to defer paying the tax by reinvesting the proceeds in an EIS Scheme - but the legislation contains a small trap...
We have seen in previous articles how the degrouping rules operate to prevent the use of a corpor... more We have seen in previous articles how the degrouping rules operate to prevent the use of a corporate vehicle to shelter taxable gains. There are two sets of rules, one for capital assets and the other for intangibles (“IP”). In this article we shall look at how these rules differ, giving a specific example involving a business sale.
In this article, we shall discuss the degrouping rules as they apply to intangible assets , such ... more In this article, we shall discuss the degrouping rules as they apply to intangible assets , such as IP and goodwill (collectively referred to as IP). The tax treatment is similar to that applying to capital assets, but with important differences.
This is the third article in our series on corporate tax groups where we explore the rules govern... more This is the third article in our series on corporate tax groups where we explore the rules governing intra-group transactions, and how they are taxed. In this article we shall look at the rules relating to capital assets.
In this paper we shall look at the legislation and see how it ensures that (1) Intra-group transa... more In this paper we shall look at the legislation and see how it ensures that (1) Intra-group transactions are tax neutral, so that (2) The tax that would otherwise have been payable is collected only when the asset leaves the group.
This is the first of a series of articles on the taxation of corporate groups. The main theme of ... more This is the first of a series of articles on the taxation of corporate groups. The main theme of these articles is that intra-group transactions are tax neutral. The first article sets out what it means to be a group.
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Papers by Satwaki Chanda