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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
Momentum has started to build in the establishment of the new Private Intermittent Securities and Capital Exchange System (PISCES), with confirmation that the legislation establishing the PISCES ‘sandbox’ will come into force on 5 June 2025 and recent guidance from HMRC on how PISCES trading events will interact with discretionary tax advantaged share schemes. PISCES is the framework for a new type of trading platform that will enable intermittent trading of private company shares.
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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
I’ve been looking at the DOTAS guidance changes (updated 14 May 2025, see bit.ly/DOTAS-guidance), and I thought it might be interesting to share an observation that HMRC’s guidance contains a quote from a case that is not actually found in the decision.
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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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2 weeks ago |
taxjournal.com | Liz Hunter |Dan Neidle |Peter Vaines |Greg Smythe
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Once you have registered, you will receive an email directing you back to read this article in full.
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3 weeks ago |
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
In T Eyre and others v HMRC[2025] UKFTT 566 (TC)(22 May) the First-tier Tribunal (FTT) held that the appellants were not entitled to entrepreneurs’ relief on disposals of shares in a property company. Although the company was preparing to carry on a trade its activities during the relevant period included to a substantial extent non-trading activities. As such it was not a ‘trading company’ for the purposes of the relief.
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3 weeks ago |
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
The Financial Times reports (2 June) that ‘Keir Starmer has rejected calls from senior Labour figures to fill a growing fiscal hole with big tax rises, warning “we can’t tax our way to growth”.’ Starmer is correct. We can’t tax our way to growth. But we can ‘tax reform’ our way to growth. Some ideas:Corporation tax simplification. The UK corporate tax system is currently less competitive than Italy or Greece, never mind Sweden and Denmark. Eliminate crazy high income tax marginal rates.
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3 weeks ago |
taxjournal.com | Greg Smythe |Liz Hunter |Dan Neidle |Peter Vaines
A recent Court of Appeal decision has clarified the process for determining whether overseas dividends are income or capital in nature, which is determinate of how the recipient should be taxed in the UK. That said, both identifying and answering the key questions involved remains inherently complex. In my experience, the tax treatment of distributions from overseas companies – particularly for corporates, though equally relevant to individuals – is often assumed, rather than properly analysed.
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3 weeks ago |
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
The UK tax landscape is undergoing one of its most significant shifts in decades. Since April 2025, the concept of domicile – long a cornerstone of the UK’s tax system – has effectively been abolished looking forward for tax purposes. In its place, a new regime based on residence has taken over, reshaping how rules on foreign income, gains and IHT are applied to individuals with international ties. But does this mean domicile is truly dead? Not quite.