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New restrictions on the amount of brought forward corporation tax losses which can be offset in any one year took effect from 1 April 2017.

New restrictions on the amount of brought forward corporation tax losses which can be offset in any one year took effect from 1 April 2017.

Policy approach

The purpose of this new measure is to ensure that Entrepreneurs’ Relief (ER) does not act as a barrier to growth for firms seeking additional external investment where the

In August 2018 HMRC issued the following statement to CIOT, ATT and other professional bodies clarifying in what circumstances they will consider giving a clearance in respect of ‘incorporation rel

1. CTM36330 ‘Condition C: ‘involved with’

In all three examples, the words ‘the carrying on

The ATT and CIOT have responded to the HMRC consultation on the taxation of self-funded, work-related training costs.

As many readers will be aware, a Follower Notice (FN) can be given where the ‘principles or reasoning‘ in a relevant judicial ruling would, if applied to the taxpayer’s chosen arrangements, deny hi

Our response was based on feedback from members in practice providing advice to clients on the EIS rules and qualifying conditions.

Both the CIOT and ATT have responded to the consultation ‘Financing growth in innovative firms: allowing Entrepreneurs’ Relief on gains made before dilution’.

HMRC launched a consultation titled Tax avoidance involving profit fragmentation on 10 April 2018.