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Author: Gavin Stebbing

Blog | 7 Mins Read

The gift that keeps on giving

The issue At last, we have an interesting inheritance tax case which is a rare thing indeed. This is an unusual one

Blog | 4 Mins Read

Is there a four-year deadline for Transactions in Securit...

The issue Transactions in securities legislation (‘TISL’) is anti-avoidance legislation whereby in certain circumstances HMRC can stop a ...

Blog | 5 Mins Read

Uncertainty around whether interest has a UK source

The issue There is tax legislation (ITA 2007 section 874) which dictates that tax needs to be withheld from certain interest payments

Blog | 4 Mins Read

What were the budget changes to company reconstructions a...

The Issue On Wednesday, many of you may not have noticed a few changes to anti-avoidance rules relating to company reconstructions, but

Blog | 3 Mins Read

Don’t forget about BADR in transactions

The issue Business Asset Disposal Relief (BADR), previously known as Entrepreneurs’ Relief is possibly nearing extinction. It was not lon...

Blog | 3 Mins Read

Beware of ‘limitation of relief’ clauses in tax treaties

The issue There are many tax treaties between the UK and various different countries. These are agreements between the countries about who

Blog | 3 Mins Read

Angela Rayner forced to resign as deputy prime minister f...

The issue The issue all revolves around the stamp duty land tax (‘SDLT’) position on Angela Rayner’s purchase of a seaside flat in

Blog | 3 Mins Read

AI chatbot’s fantasy tax cases cost taxpayer £13k

A recent First-tier Tribunal has shone a light on the growing risks of taxpayers turning to artificial intelligence for self-help. In HMRC

Blog | 4 Mins Read

When inheritance tax can be helpful in a company purchase...

The issue On a purchase of own shares by a company the default position is that any profit over and above the

Blog | 4 Mins Read

Tribunal intervenes in SDLT case

The issue A recent SDLT case (Sajedi) considered the position of a tax loophole where the taxpayers lost. This involved the ability to

Blog | 5 Mins Read

The great pension 70.5% tax raid of 2024

The issue When Rachel Reeves casually announced on Wednesday that pensions would be subject to 40% inheritance tax (‘IHT’), I was unsurpr...

Blog | 2 Mins Read

Non-UK domiciled beneficiaries may want to ‘raid...

The issue The temporary repatriation facility (TRF) which was announced on 30 October 2024 was a rare piece of welcome news for