Loans to participators: charge on upstream loans
Where a loan to a participator in a close company remains outstanding nine months after the balance sheet date, the company making the loan is required to make a payment to HMRC equivalent to33.75%
Where a loan to a participator in a close company remains outstanding nine months after the balance sheet date, the company making the loan is required to make a payment to HMRC equivalent to33.75%
The Welsh government recently consulted on proposals to abolish land transaction tax(LTT) multiple dwellings relief (MDR) following the UK government’s decision to abolish the equivalent relief for
Finance (No.2) Act 2024received Royal Assent on 24 May 2024.
In 2018, the CIOT made a proactive submission to HMRC about the capital gains tax (CGT) trap on refinancing property using alternative (Shariah compliant) finance (see Mohammed Amin’s article in
CIOT continues to engage with HMRC to address the challenges arising because of the ‘volume compliance’ approach for enquiries into R&D tax relief claims.
As all members of CIOT and ATT will be aware, the duty to manage their professional risk is an increasing obligation.
The progress of artificial intelligence (AI) is well documented, and the impact on tax professionals will continue to evolve.
The CIOT has written to HMRC about uncertainties in the application of ESC D32 on the incorporation of a business, where an individual transfers the whole of the assets and liabilities to a company
The start date for the new merged research and development (R&D) scheme was confirmed early in March: the new scheme will apply for accounting periods beginning on or after 1 April 2024.