HMRC have recently published new guidance (available here) on the VAT and SDLT implications of certain lease variations. In spite of HMRC’s statement that there is no change in policy, the VAT guidance represents a move away from what many advisers might previously have considered the position to be on certain lease amendments, where each party “gives something” to the other. The new guidance has...
Read moreAs has been widely publicised, the Chancellor announced a temporary reduction in the rates of residential SDLT** as part of the government’s “mini-Budget”. The nil rate band for all residential property will be increased to £500,000 (from £125,000) effective immediately and until 31 March 2021, in the hopes of both supporting the housing market as it recovers from its hibernation during the...
Read moreWe have received the anticipated, but long-awaited, welcome confirmation that where an individual has not been required to work for reasons connected with coronavirus, this will not (in itself) mean that the individual fails to meet the working time requirement for EMI purposes. The confirmation comes by way of amendments to the Finance Bill 2020, which will receive Royal Assent this summer and...
Read moreCovid-19 is creating challenges for the whole country, but there will undoubtedly also be some opportunities too. This tax bite looks briefly at some of the tax-related opportunities that could exist in relation to property in the current climate. With predictions that property prices may reduce in the short term as a result of Covid-19, now may be a good time to consider extracting expensive...
Read moreDemergers are popular from a tax perspective as, broadly speaking, provided they are correctly structured they can allow for the separation of trades / businesses (including investment businesses) with no or minimal tax leakage. This can allow one trade to be sold, attract investment or be ring-fenced separately from another trade or business / asset. In the current business and economic climate,...
Read moreHMRC have released their latest Employment Related Securities bulletin confirming the treatment of certain tax advantaged share schemes where participating employees may have been furloughed or otherwise financially impacted by Covid-19. In it they have confirmed that options granted under Company Share Option Plans (CSOPs) to employees and full-time directors who have been furloughed because of...
Read moreSEIS/EIS remains a very powerful tool for attracting investors and de-risking their investment to an extent. SEIS offers a 50% relief and EIS offers a 30% relief - this means that an amount equal to 50%/30% (as applicable) of the amount invested can be set against the investor’s income tax bill. If the investment is not successful and losses are made, the losses (less any relief claimed) can be...
Read moreEMI options are a great way of delivering shares to employees. They are tax efficient, straightforward to implement and flexible. It is possible to agree the share value with HMRC before the options are granted (which is very attractive as that means there is certainty of tax treatment) and they can be put in place relatively cheaply. In most cases if a company qualifies to grant EMI options,...
Read moreAs the country faces economic uncertainty, which may mean some businesses look to restructure or refinance their debts, we thought it would be helpful to outline the rules around when individuals and trustees can get tax relief for debts that may be, or become, irrecoverable. We will not touch on lending between companies in this Bite, which was the subject of a recent Tax Bite and is available...
Read moreWith all businesses more focussed at this time on cash reserves and potentially faced with having to make difficult decisions about their people, we are finding that companies are thinking about EMI options and the ability to reward employees with equity based awards. They are being used as an alternate remuneration strategy for example to compensate staff for temporarily taking a lower salary or...
Read moreHMRC have introduced new temporary, emergency processes around stamping documents as a result of coronavirus measures, which new processes will remain in force until these measures end – although it is not clear at this stage what is meant by that. What it does mean is that with immediate effect HMRC will not be physically stamping documents and the new processes, summarised below, should be used...
Read moreCompanies with valuable property (or other) assets sat in their trading companies should consider reorganising their structure to try to ring-fence these valuable assets from trading risk. If there is already a group structure, then it should be relatively straightforward to transfer assets to achieve this commercial aim. There are some tax points to consider before doing so, not least VAT and...
Read moreParisi Tax is a specialist tax law firm. Our clients benefit from having on-demand access to a wealth of tax knowledge and deal expertise.
Services