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Where Taxpayers and Advisers Meet

Search found 56 matches

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by simplytax
Wed Jun 05, 2013 8:55 pm
Forum: Company Taxation
Topic: Unrealised Forex Gains/Losses
Replies: 2
Views: 2305

Re: Unrealised Forex Gains/Losses

If under proper GAAP the gains/losses are recorded in the accounts based on year end translation rate then if intercompany debt that is not trading the gains/losses would be non trading loan relationship credits or debits.
by simplytax
Wed Jun 05, 2013 8:14 pm
Forum: International Tax
Topic: Uk national going to work rotation Angola
Replies: 3
Views: 1494

Re: Uk national going to work rotation Angola

Satisfying the full time working overseas test requires in the first instance satisfying sufficient hours worked overseas to give avarage of 35 hours per week. The calculation of this is laid down in the legislation starting with 365 days and making deductions for holidays and days worked in UK. If ...
by simplytax
Wed Jan 16, 2013 6:17 pm
Forum: Capital Gains Tax, CGT
Topic: capitalisation of loan by shareholder(not original Creditor)
Replies: 1
Views: 580

capitalisation of loan by shareholder(not original Creditor)

Mr A and Mr B were equal shareholders in Co D which was sold some years ago. Co D had lent some money to Co. E but on the sale of Co. D the loans of face value £300k were assigned equally to Mr A and Mr B at a 40% discount to their face value ie £180k as Co E was in deficit trying to establish a new...
by simplytax
Fri Jun 24, 2011 5:45 pm
Forum: Business Tax
Topic: P11D Benefits for deceased
Replies: 2
Views: 2239

Re: P11D Benefits for deceased

Tax return fees for director where company had contracted for the service for tax return for the tax year prior to that in which he died. If company pays the fee after date of death then presumably not a BIK in tax return to date of death but still a reportable P11D BIK for the tax year ? Does it fa...
by simplytax
Fri Jun 24, 2011 1:52 pm
Forum: Business Tax
Topic: P11D Benefits for deceased
Replies: 2
Views: 2239

P11D Benefits for deceased

If benefit in kind is paid by employer after date employee died is it reportable on P11D ?
by simplytax
Fri Jan 28, 2011 8:26 pm
Forum: Capital Gains Tax, CGT
Topic: Loss on shares as income loss
Replies: 2
Views: 912

Loss on shares as income loss

Under s131 ITA 2007 a loss on shares in an unquoted trading company can qualify as an income loss. What is a qualifying trading company ? Is the company required to have been trading or is it sufficient that it was set up to trade and had incurred initial costs and professional fees etc but had not ...
by simplytax
Tue Oct 26, 2010 3:10 pm
Forum: Company Taxation
Topic: Salary v dividend
Replies: 0
Views: 740

Salary v dividend

If the sole shareholder and director of a small trading company currently takes £50k as salary decides to reduce this to a salary of £5715 ( NIC threshold) and then take dividends in future are there any problems with this approach as it will give a saving in tax and NIC of around £8k pa ? As owner ...
by simplytax
Thu Oct 07, 2010 2:23 pm
Forum: International Tax
Topic: Withholding Tax - Unilateral Relief
Replies: 3
Views: 1310

Re: Withholding Tax - Unilateral Relief

If the trading losses b/f exceed the trading profits of the year then the WHT will require to be claimed as an expense ( s35 TIOPA 2010 ) thereby increasing the trading loss to carry forward. If you were to disclaim say capital allowances or other reliefs in the current year and this resulted in an ...
by simplytax
Thu Oct 07, 2010 2:13 pm
Forum: International Tax
Topic: Withholding tax claimed against Corporation tax
Replies: 1
Views: 2337

Re: Withholding tax claimed against Corporation tax

A specific claim for double tax relief as a deduction under s798( C ) ICTA 1988 [ now s35 TIOPA 2010 ] should result in the WHT increasing the trading loss to carry forward to set against future profits. This assumes the WHT was properly chargeable by the customer in the first place or there was not...
by simplytax
Thu Sep 09, 2010 11:15 am
Forum: Company Taxation
Topic: Employee entertaining
Replies: 2
Views: 1061

Re: Employee entertaining

I don't think there should be a problem with CT deduction if been treated as a BIK as effectively it is part of incentive/remuneration package and as such W&E test satisfied. http://www.hmrc.gov.uk/manuals/bimmanual/BIM45033.htm http://www.legislation.gov.uk/ukpga/2009/4/section/1299 I assume that t...

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