In Delinian Limited (formerly Euromoney Institutional Investor PLC) v HMRC [2023] EWCA Civ 1281, the Court of Appeal (CoA) held that although structuring a deal to allow non-payment of tax through the Substantial Shareholdings Exemption (SSE) rules was tax avoidance, it was not one of the main purposes of the transaction so the deferred gain was allowed.
SME Tax News
In Abigail Wilmore v HMRC [2023] TC08959, the First Tier Tribunal (FTT) found that a divorcing couple’s agreement over the division of properties had created a constructive trust. This amounted to a disposal for Capital Gains Tax purposes, allowing no gain/no loss treatment to apply.
The Scottish Parliament has announced that its 2023 Budget will be held on Tuesday 19 December 2023. This will set the tax and spending plans for Scotland for 2024-25.
Hello,
The weeks are flying by at the moment, Halloween and World National Savings Day, both on 31 October, have now passed and today the Bank of England has again frozen interest rates in its penultimate rate review for 2023.
HM Treasury has issued its latest Women in Finance Charter signatory survey with 65% of respondents saying that the charter has driven permanent change in their organisation. It is helping them maintain focus on increasing female representation in the sector as they move into the next phase of their diversity efforts.
The International Tax Competitiveness Index 2023, compiled by the Tax Foundation, has seen Estonia top the league for the tenth year in a row, making it an ideal destination for those looking to live, work and set up businesses overseas, as well as digital nomads.
In McEnroe & Newman v HMRC [2023] UKUT 255, the Upper Tribunal (UT) refused the taxpayer's appeal on the basis that the First Tier Tribunal (FTT) had not erred in law in failing to interpret a Share Sale & Purchase Agreement (SPA) in a manner that reduced the consideration by over £1 million.
The Economic Crime and Corporate Transparency Act, which gained Royal Assent last week, includes measures to help Companies House close loopholes on identity verification for all new and existing registered company directors and people with significant control, including overseas entities.
Missed our SME Tax Web-updates in October? Here is a summary of the month.
HMRC are changing their online advice pages and letters to clients on agent authorisation clarifying what agents can and cannot do when they are working via the Online Agent Authorisation system. They stress the need for clients to check their tax returns before allowing their agents to submit them on their behalf.