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Where Taxpayers and Advisers Meet

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by simplytax
Sun Jan 17, 2016 7:18 pm
Forum: Professionals in Practice & Industry
Topic: unagreed partnership accounts and overpayment relief claim
Replies: 0
Views: 2870

unagreed partnership accounts and overpayment relief claim

If following the retirement of a partner from a professional partnership the closing wip in the accounts for the clients he dealt with for the year of leaving has not been agreed by him and the accounts and the profit allocation not finalised within the period for amendment of the partnership tax re...
by simplytax
Sun Jan 17, 2016 7:16 pm
Forum: Income Tax
Topic: Overpayment relief claim where partnership accounts unagreed
Replies: 0
Views: 467

Overpayment relief claim where partnership accounts unagreed

If following the retirement of a partner from a professional partnership the closing wip in the accounts for the clients he dealt with for the year of leaving has not been agreed by him and the accounts and the profit allocation not finalised within the period for amendment of the partnership tax re...
by simplytax
Tue May 19, 2015 6:47 pm
Forum: Income Tax
Topic: Restricted Securities ?
Replies: 0
Views: 413

Restricted Securities ?

Parent company sells all of shares in a subsidiary to existing directors of subsidiary. Price payable was lent to the directors under a loan agreement and a separate share pledge with the shares offered as security until the loan is repaid. The shares acquired by the directors are Employment Related...
by simplytax
Wed Oct 29, 2014 8:14 pm
Forum: Company Taxation
Topic: Transfer Pricing
Replies: 1
Views: 768

Re: Transfer Pricing

See HMRC manuals re TP enquiries http://www.hmrc.gov.uk/manuals/intmanual/intm501020.htm Why do you believe loan relationships are excluded from TP? The intercompany balances are likely to comprise loan relationships where there have been cash advances ie lending of money or deemed LR where debts of...
by simplytax
Wed Oct 08, 2014 6:45 pm
Forum: Company Taxation
Topic: Close company reorganisation and anti-avoidance
Replies: 0
Views: 818

Close company reorganisation and anti-avoidance

Close company "A" with trade and rental business is considering ceasing the trade and continuing with the rental business. Suggestion made was to sell the properties at MV to a Newco with consideration left outstanding and company "A" then liquidated with the debt due from Newco distributed in speci...
by simplytax
Thu Mar 27, 2014 6:10 pm
Forum: Company Taxation
Topic: Loan relationship trade or non trade debit
Replies: 18
Views: 5355

Re: Loan relationship trade or non trade debit

An interesting dialogue and views. It may not be uncommon for companies with mixed investment and trading activities to borrow money to meet working capital part of which is used to pay a CT bill or in this case to borrow specifically to meet a CT bill. If part is unsecured and part secured over inv...
by simplytax
Thu Mar 20, 2014 6:28 pm
Forum: Company Taxation
Topic: Loan relationship trade or non trade debit
Replies: 18
Views: 5355

Re: Loan relationship trade or non trade debit

Lambs - thanks for the considered thoughts on this but if HMRC were of the view that you can dissect the CT liability between trading and non trading as a basis of apportioning interest paid on a loan borrowed to pay the CT liability, how does that square with the fact that interest on late paid CT ...
by simplytax
Thu Mar 06, 2014 12:04 pm
Forum: Company Taxation
Topic: Loan relationship trade or non trade debit
Replies: 18
Views: 5355

Re: Loan relationship trade or non trade debit

Where does it say that the use of the money borrowed has to be a tax deductible expense? A wholly trading company may borrow to acquire an asset to be used in the trade but the asset would not be a tax deductible expense. The interest on the loan to acquire the asset however would be a trade LR debi...
by simplytax
Wed Mar 05, 2014 7:19 pm
Forum: Company Taxation
Topic: Loan relationship trade or non trade debit
Replies: 18
Views: 5355

Loan relationship trade or non trade debit

If a company borrows money to pay CT to HMRC is the interest payable trade or non trade where the company has both investment and trading activities ? Are you expected to dissect the CT liability between trade and non trade elements to determine the purpose and use of the money borrowed? If interest...
by simplytax
Fri Aug 23, 2013 1:54 pm
Forum: Company Taxation
Topic: Filing CT return with draft accounts
Replies: 0
Views: 602

Filing CT return with draft accounts

If a company audit cannot be completed within two years of the APE can the latest Draft accounts be lodged under IXBRL ( or as pdf ) if approved by the directors so as to meet the 2 year time limit for certain claims for tax relief to be made in a tax return eg capital allowances. Any revision to th...

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