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Where Taxpayers and Advisers Meet

Search found 56 matches

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by simplytax
Wed Sep 08, 2010 6:29 pm
Forum: Company Taxation
Topic: Employee entertaining
Replies: 2
Views: 1056

Employee entertaining

If shareholder director and 2 of the employees who hold small number of shares go overseas on a fishing trip where part leisure trip but also discuss company business what is tax treatment ? If not open to all employees and not covered by £150 per head then presumably total cost of trip is a BIK on ...
by simplytax
Tue Apr 27, 2010 2:56 pm
Forum: Company Taxation
Topic: Property business debts written back and credits in accounts
Replies: 0
Views: 540

Property business debts written back and credits in accounts

If a property rental business has a creditor to pay a rent rebate and a rent deposit due to a connected company that has now been struck off at Companies House how are the credits treated on writing back the creditors in its accounts? It would appear that money debts that are trade or property busin...
by simplytax
Sun Apr 04, 2010 12:36 pm
Forum: Company Taxation
Topic: EIS and connected person
Replies: 1
Views: 595

EIS and connected person

An SME in financial difficulty appoints a new CEO to help trun things around and invest himself and obtain new investors. Within months of being appointed, the restructuring plan agreed with the bank is for a Newco to be set up which will acquire Oldco. Newco has new investors including the CEO as w...
by simplytax
Sun Apr 04, 2010 12:35 pm
Forum: Income Tax
Topic: EIS and connected person
Replies: 0
Views: 446

EIS and connected person

An SME in financial difficulty appoints a new CEO to help trun things around and invest himself and obtain new investors. Within months of being appointed, the restructuring plan agreed with the bank is for a Newco to be set up which will acquire Oldco. Newco has new investors including the CEO as w...
by simplytax
Sat Apr 03, 2010 6:06 pm
Forum: Company Taxation
Topic: EMI and overseas activities
Replies: 0
Views: 427

EMI and overseas activities

1. If a UK incorporated SME has its premises in the UK and over the years the level of consulting services provided to customers has moved from being carried out mainly in the UK to mainly overseas, whilst I understand that may previously have denied the use of an EMI scheme to incentivise key emplo...
by simplytax
Tue Mar 02, 2010 11:43 am
Forum: Company Taxation
Topic: Interest free loan UK to UK and transfer pricing
Replies: 8
Views: 3155

Re: Interest free loan UK to UK and transfer pricing

Thanks for your comments Incredulum. These issues as like a lot in tax can get very convoluted in theory with uncertainty on how practical HMRC will be in practice. Any loss in the shares, whether or not the loan is capitalised if between two trading companies I expect would fall under SSE provision...
by simplytax
Mon Mar 01, 2010 7:53 pm
Forum: Company Taxation
Topic: Interest free loan UK to UK and transfer pricing
Replies: 8
Views: 3155

Re: Interest free loan UK to UK and transfer pricing

On contacting HMRC TP unit to discuss their general approach in UK to UK interest free loans, if when the loan is made the two companies document the long term nature and equity function it is performing and no interest is to be charged then that should suffice. The position should be reviewed perio...
by simplytax
Tue Feb 09, 2010 7:33 pm
Forum: Company Taxation
Topic: Interest free loan UK to UK and transfer pricing
Replies: 8
Views: 3155

Re: Interest free loan UK to UK and transfer pricing

Thanks for your comments. How do you generally go about supporting the arms length amount of loan and interest to satisfy HMRC? Its not that long ago that banks were falling over themselves to lend and now they won't lend ! If sub set up with small equity and not forecasting profits for several year...
by simplytax
Tue Feb 09, 2010 12:11 pm
Forum: Company Taxation
Topic: Interest free loan UK to UK and transfer pricing
Replies: 8
Views: 3155

Interest free loan UK to UK and transfer pricing

If UK parent funds the set up of its UK sub and there is a large intercompany balance with no interest applied then one would expect there to be an imputation of interest ( where SME thresholds exceeded ) for transfer pricing on the parent as lender and the sub can claim a compensating adjustment. H...
by simplytax
Sat Jan 16, 2010 9:10 pm
Forum: Capital Gains Tax, CGT
Topic: Buying parents house and declaration of trust
Replies: 4
Views: 1119

Re: Buying parents house and declaration of trust

To clarify. Son acquires title to his parents house and pays then the market value and minute of agreement drawn up that parents will continue to live in it rent free and will meet maintenance costs. Now considering drawing up a Declaration Of Trust to this effect to hopefully strengthen claim for m...

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