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Nov 14, 2024 | 
taxjournal.com | Sarah Ling |Andrew Marr |Julian Feiner |Mike Lane
In Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC) (1 November) the First-tier Tribunal (FTT) dismissed Syngenta Holdings Ltd’s (SHL) appeal against closure notices denying corporation tax deductions for loan interest on the basis that SHL was party to the loan for an unallowable purpose. The context was that SHL acquired the entire issued share capital of its sister company Syngenta Ltd (SL) from its immediate parent company Syngenta Alpha BV (SABV).
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Nov 12, 2024 | 
taxjournal.com | Sarah Ling |Andrew Marr |Julian Feiner |Mike Lane
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Nov 7, 2024 | 
taxjournal.com | Julian Feiner |Mike Lane |Laura Charkin |Sophie Dworetzsky
The NFU’s president Tom Bradshaw has demanded that the new IHT APR rules be withdrawn and put to consultation with the agricultural industry and Defra experts rejecting Treasury claims that 72% of farms will not be paying IHT under the new regime.
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Nov 6, 2024 | 
taxjournal.com | Andrew Marr |Sarah Ling |Julian Feiner |Mike Lane
When Rachel Reeves casually announced last Wednesday that pensions would be subject to 40% IHT, I was unsurprised. Currently, when an individual aged 75 or over dies, no IHT is charged on their pension fund. However, there is an income tax charge on the beneficiaries at their marginal rate when benefits are withdrawn from the pension. I therefore assumed that these changes would see HMRC take a 40% tax payment immediately, leaving beneficiaries with the remaining 60%. That may have been fair.
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Nov 6, 2024 | 
taxjournal.com | Helen McGhee |Sarah Ling |Andrew Marr |Julian Feiner
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Nov 6, 2024 | 
taxjournal.com | Sarah Ling |Andrew Marr |Julian Feiner |Mike Lane
HMRC have issued new guidance setting out how businesses should submit their VAT returns if they are exempt from using compatible software for Making Tax Digital for VAT.
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Nov 6, 2024 | 
taxjournal.com | Sarah Ling |Andrew Marr |Julian Feiner |Mike Lane
The ‘loan to participator’ rules are a long-standing set of rules designed to prevent closely controlled (for example, owner-managed) companies deferring tax on dividends by making loans to shareholders instead. Fact patterns in scope of these rules range from simple to highly complex, and the changes announced today could make those examples at the more difficult end of the spectrum even more complex.
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Nov 6, 2024 | 
taxjournal.com | Adam Craggs |Liam McKay |Julian Feiner |Mike Lane
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Nov 6, 2024 | 
taxjournal.com | Julian Feiner |Mike Lane |Laura Charkin |Sophie Dworetzsky
Home >Articles > CGT anti-forestalling measures CGT anti-forestalling measures 6 November 2024 As announced in the Budget, the following headline rates of CGT are changing: an immediate increase to CGT rates: from 10% to 18% for basic rate taxpayers and from 20% to 24% for higher rate taxpayers; business asset disposal relief will change (from 6 April 2025) from 10% to 14%; and from 14% to 18% from 6 April 2026; and carried interest CGT rates will increase from 28% to 32% from 6 April 2025...
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Nov 6, 2024 | 
taxjournal.com | Sarah Ling |Julian Feiner |Mike Lane |Laura Charkin
In Procurement International Ltd v HMRC [2024] UKFTT 949 (TC) (24 October) the FTT decided that the appellant was entitled to zero rate supplies of goods that had been exported because it found that the appellant was the exporter. The appellant supplied goods to reward programme operators (RPOs) who made onward supplies of the goods to employers.
