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Category: Blog

Blog | 4 Mins Read

How a demolition job can lose your PPR

The issue Most property developers are conscious of the fact that stamp duty land tax (SDLT) rates are lower for bare pieces

Blog | 5 Mins Read

To have and to hold (over)

The issue With BPR planning now reaching frenzied levels before 5 April 2026, even with the increase in value of the 100%

Blog | 3 Mins Read

Tax mysteries surrounding distributions from companies li...

The issue Companies which are limited by guarantee do not have shareholders and instead have members who act as guarantors. These kinds

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

How loans can deny the Substantial Shareholding Exemption...

The issue The Substantial Shareholding Exemption (SSE) should generally apply to disposals by companies of trading subsidiaries if the sh...

Blog | 3 Mins Read

Can a company holding alphabet shares benefit from the Su...

The issue The Substantial Shareholding Exemption (SSE) can be a valuable relief when a company sells shares in a trading company (which

Blog | 4 Mins Read

The impact of the dividend tax hike on remuneration planning

The Issue Since the Budget many shareholders have been asking us whether the increase to dividend tax rates (an extra two per

Blog | 3 Mins Read

Have inter-spouse transfers of business property been a w...

The Issue Last year the Government made the unpopular announcement that Business Property Relief (BPR) would be restricted so that an ind...

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 | 4 Mins Read

The IHT sting of EOT receivables

The Issue The Employee Ownership Trust (EOT) tax provisions were enacted in 2014, as a way to encourage long-term employee ownership in

Blog | 4 Mins Read

Get the FOTRA out of the UK! – You will want to rea...

The issue Hidden within the Finance Act 2025 was a very helpful change to the tax treatment of UK government securities for

Blog | 5 Mins Read

Should Property 118 clients sell up?

The issue A number of Property 118 (‘P118’) clients have received enquiries recently. These enquiries all revolve around the availability...