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Accountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates.2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning toTECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy.MARK WILLIAMS
Mark’s work has a corporate focus and his clients include entrepreneurs, families and their businesses, and private investors. Mark works across a range of industry sectors. Many of his clients operate in service industries, including financial services, and in property investment and development. He is a multi-specialist, covering corporate and personal tax and accounting matters for hisSOPHIE LEMAITRE
Sophie Lemaitre. Partner (Paris) Sophie joined Dixon Wilson in 1998 and became the firm’s first French partner in 2004. She is based in the Paris office and speaks English fluently. Sophie advises French companies and other businesses with a French activity. Her work involves daily contact with companies based in the UK, in the US, butalso
DAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactions NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxationPARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
TECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy.SOPHIE LEMAITRE
Sophie Lemaitre. Partner (Paris) Sophie joined Dixon Wilson in 1998 and became the firm’s first French partner in 2004. She is based in the Paris office and speaks English fluently. Sophie advises French companies and other businesses with a French activity. Her work involves daily contact with companies based in the UK, in the US, butalso
MARK WILLIAMS
Mark’s work has a corporate focus and his clients include entrepreneurs, families and their businesses, and private investors. Mark works across a range of industry sectors. Many of his clients operate in service industries, including financial services, and in property investment and development. He is a multi-specialist, covering corporate and personal tax and accounting matters for hisDAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactionsHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxationPARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
TECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy.SOPHIE LEMAITRE
Sophie Lemaitre. Partner (Paris) Sophie joined Dixon Wilson in 1998 and became the firm’s first French partner in 2004. She is based in the Paris office and speaks English fluently. Sophie advises French companies and other businesses with a French activity. Her work involves daily contact with companies based in the UK, in the US, butalso
MARK WILLIAMS
Mark’s work has a corporate focus and his clients include entrepreneurs, families and their businesses, and private investors. Mark works across a range of industry sectors. Many of his clients operate in service industries, including financial services, and in property investment and development. He is a multi-specialist, covering corporate and personal tax and accounting matters for hisDAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactionsHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning to CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. DEMERGERS - CAPITAL REDUCTION DEMERGER A capital reduction demerger is an alternative to a statutory demerger where the requirements of the latter cannot be met. In practice there are two main reasons why a statutory demerger is not possible, either because there are companies in the group that are not trading companies, or because the demerger is in anticipation of a sale of oneor
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobile DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
TECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy.SOPHIE LEMAITRE
Sophie Lemaitre. Partner (Paris) Sophie joined Dixon Wilson in 1998 and became the firm’s first French partner in 2004. She is based in the Paris office and speaks English fluently. Sophie advises French companies and other businesses with a French activity. Her work involves daily contact with companies based in the UK, in the US, butalso
MARK WILLIAMS
Mark’s work has a corporate focus and his clients include entrepreneurs, families and their businesses, and private investors. Mark works across a range of industry sectors. Many of his clients operate in service industries, including financial services, and in property investment and development. He is a multi-specialist, covering corporate and personal tax and accounting matters for hisDAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactionsHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris.2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning toHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobilePAUL HOWARD
Paul is a Chartered Accountant and Fellow of the Chartered Institute of Taxation, with over 30 years’ experience in advising clients and other professionals on a wide range of complex tax issues. He joined Dixon Wilson as a director in 2019, where he provides tax technical support for the firm. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates.STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxationFRANCIS KERSHAW
Francis has over 15 years of experience advising families, trusts and entrepreneurial businesses on all aspects of their UK tax and accounting needs. Francis qualified at PricewaterhouseCoopers first as a Chartered Accountant and then as a Chartered Tax Adviser, advising internationally-mobile executives on their personal tax position and assisting businesses on compliance with cross-border HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris.2021 BUDGET UPDATE
The temporary increase of the nil rate band, from £125,000 to 500,000, which was due to end on 31 March 2021 has been extended to 30 June 2021. From 1 July 2021 to 30 September 2021 the nil rate band will reduce to £250,000, before returning toHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
UK TAX DATA CARD 2021/22 Please click the download PDF button to view the UK Tax Data Card 2021/22. There is also a version of the tax data card which should be easier to read on a mobilePAUL HOWARD
Paul is a Chartered Accountant and Fellow of the Chartered Institute of Taxation, with over 30 years’ experience in advising clients and other professionals on a wide range of complex tax issues. He joined Dixon Wilson as a director in 2019, where he provides tax technical support for the firm. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates.STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxationFRANCIS KERSHAW
Francis has over 15 years of experience advising families, trusts and entrepreneurial businesses on all aspects of their UK tax and accounting needs. Francis qualified at PricewaterhouseCoopers first as a Chartered Accountant and then as a Chartered Tax Adviser, advising internationally-mobile executives on their personal tax position and assisting businesses on compliance with cross-border PEOPLE | DIXON WILSON Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
MARK WILLIAMS
Mark’s work has a corporate focus and his clients include entrepreneurs, families and their businesses, and private investors. Mark works across a range of industry sectors. Many of his clients operate in service industries, including financial services, and in property investment and development. He is a multi-specialist, covering corporate and personal tax and accounting matters for his CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes.SOPHIE LEMAITRE
Sophie Lemaitre. Partner (Paris) Sophie joined Dixon Wilson in 1998 and became the firm’s first French partner in 2004. She is based in the Paris office and speaks English fluently. Sophie advises French companies and other businesses with a French activity. Her work involves daily contact with companies based in the UK, in the US, butalso
NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).PAUL HOWARD
Paul is a Chartered Accountant and Fellow of the Chartered Institute of Taxation, with over 30 years’ experience in advising clients and other professionals on a wide range of complex tax issues. He joined Dixon Wilson as a director in 2019, where he provides tax technical support for the firm.DAVID NELSON
David was previously Senior Partner, serving from 2008 to 2018. David has expertise in helping wealthy families, and their businesses, and Landed Estates concerning tax and other aspects of their financial and business affairs, leading a team which works closely with clients and other professional advisors.STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxation DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
JAMES KIDGELL
James trained at Dixon Wilson, joining in 1997, and is based in the London office. His expertise lies in UK and international financial and tax planning and compliance for private clients. James’s professional work focuses on structures employed in tax planning, wealth protection and philanthropy for UK and non-UK domiciled clients, their trusts, charities and businesses. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).GREGORY SMYE-RUMSBY
Gregory advises a range of private clients on their financial and tax affairs. This is focused on individuals and families and their financial interests including private companies, trusts and charities. It includes both compliance and advice. He is often advising landed estates, entrepreneurs and their businesses, and non-UK domiciled individuals who are moving to the UK . HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
JAMES KIDGELL
James trained at Dixon Wilson, joining in 1997, and is based in the London office. His expertise lies in UK and international financial and tax planning and compliance for private clients. James’s professional work focuses on structures employed in tax planning, wealth protection and philanthropy for UK and non-UK domiciled clients, their trusts, charities and businesses. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).GREGORY SMYE-RUMSBY
Gregory advises a range of private clients on their financial and tax affairs. This is focused on individuals and families and their financial interests including private companies, trusts and charities. It includes both compliance and advice. He is often advising landed estates, entrepreneurs and their businesses, and non-UK domiciled individuals who are moving to the UK .TECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
DAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactionsHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
PARTNERSHIP TAXATION For limited partners and non-active partners in the first four tax years of trade, losses are restricted to the lower of: £25,000 per year; and. The partner’s capital contributions at the end of the basis period for the relevant tax year, less any relief previouslyclaimed.
THOMAS WEST
Thomas is a general client partner providing a full range of compliance and advisory services to individuals and families, and their businesses, trusts and charities. His practice has a particular focus on landed estates, with clients including traditional large country estates, valuable urban commercial portfolios and property investment and development companies. CORPORATE INTEREST EXPENSE The worldwide debt cap rules were repealed effective from 1 April 2017 and have been replaced by the new corporate interest expense rules. The motivation behind the new rules is to restrict the amount of tax relief for interest expenditure claimed by large or multinational groups that are highly leveraged.STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxation HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
JAMES KIDGELL
James trained at Dixon Wilson, joining in 1997, and is based in the London office. His expertise lies in UK and international financial and tax planning and compliance for private clients. James’s professional work focuses on structures employed in tax planning, wealth protection and philanthropy for UK and non-UK domiciled clients, their trusts, charities and businesses. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).GREGORY SMYE-RUMSBY
Gregory advises a range of private clients on their financial and tax affairs. This is focused on individuals and families and their financial interests including private companies, trusts and charities. It includes both compliance and advice. He is often advising landed estates, entrepreneurs and their businesses, and non-UK domiciled individuals who are moving to the UK . HOME | DIXON WILSONSECTORSPEOPLEABOUT USTECHNICAL UPDATESCAREERSNEWS90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Founded in 1888, Dixon Wilson is one of the leading firms of Chartered Accountants with offices in London and Paris. PEOPLE | DIXON WILSON90210 ANNIE WILSON90210 DIXONDIXON WILSON UKDIXON WILSON CHARTERED ACCOUNTANTS Profiles of the partners and directors at Dixon Wilson CharteredAccountants.
CORPORATION TAX TREATMENT OF GOODWILL AND RELATED ASSETS The fixed rate of relief, ignoring any restriction, is 200,000 x 6.5% = £13,000. The restriction is calculated as follows: (15,000 x 6)/200,000 = 0.45. The allowable debit is reduced by the formula: 13,000 x 0.45 = £5,850, which is the allowable debit for goodwill for corporation tax purposes. NON-RESIDENT LANDLORD COMPANIES Non-resident landlord companies are currently subject to income tax at 20% on their property income, however the corporation tax rate is currently 19%. Where non-resident companies continue to have other income apart from property income, this will still be subject to income tax and will be required to be reported on a Non-ResidentCompany
JAMES KIDGELL
James trained at Dixon Wilson, joining in 1997, and is based in the London office. His expertise lies in UK and international financial and tax planning and compliance for private clients. James’s professional work focuses on structures employed in tax planning, wealth protection and philanthropy for UK and non-UK domiciled clients, their trusts, charities and businesses. BUSINESS INVESTMENT RELIEF Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions. In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to theUK, as long
PARIS OFFICE
Our partners in Paris are qualified both as British Chartered Accountants and French Experts Comptables (accountants). Our French accounting company, Dixon Wilson SARL, is registered with the French authorities to carry out accountancy assignments. Our partners and staff in Paris have been trained in a British professionalenvironment.
THE BALFOUR CASE
The Upper Tax Tribunal’s decision to dismiss HMRC’s appeal in the Balfour case has recently been published. This decision is an important one for landowners and their advisers as it potentially changes the approach to inheritance tax planning in relation to the ownership and management of landed estates. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor).GREGORY SMYE-RUMSBY
Gregory advises a range of private clients on their financial and tax affairs. This is focused on individuals and families and their financial interests including private companies, trusts and charities. It includes both compliance and advice. He is often advising landed estates, entrepreneurs and their businesses, and non-UK domiciled individuals who are moving to the UK .TECHNICAL UPDATES
The Chancellor of the Exchequer delivered his summer economic update which sets out the government’s plan for the second phase of a three phase plan for economic recovery from coronavirus. The main focus of this phase is to protect, support and create jobs for people who have been particularly impacted by the rapid contraction in the economy. DIVIDENDS AND DISTRIBUATABLE PROFITS UNDER FRS 102 A profit or loss is treated as realised in accordance with generally accepted accounting practice. For most transactions this will be obvious, following the underlying principle that profits are treated as realised only when realised in the form of cash or other assets, the ultimate realisation of which can be assessed with reasonable certainty (eg a trade debtor). DEMERGERS - THE STATUTORY ROUTE The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation underthe Insolvency
DEMERGERS - LIQUIDATION RECONSTRUCTION UNDER S 110 There are three broad routes to carrying out a demerger: The statutory route (an exempt demerger) Liquidation under the Insolvency Act 1986. Reduction of capital (a Companies Act 2006 reconstruction) This note focuses solely on the liquidation route, covering the key tax implications and the principal qualifying requirements. Part 1 andPart 3
DAVID MELLOR
David trained at Dixon Wilson, qualifying in 1994, and is based in the London office. David’s work is focused on helping private clients achieve their objectives. David achieves this through providing advice on long-term tax planning, wealth protection, and assisting in setting the overall financial strategy, as well as providing ongoing tax compliance services, and advice on transactionsHELEN CLARK
Helen trained at Dixon Wilson, joining in 1992, and is based in the London office. She advises high net worth individuals and families with interests in properties and trusts both in the UK and abroad, and she has specific expertise in the UK impact of holding wealth inoffshore trusts.
PARTNERSHIP TAXATION For limited partners and non-active partners in the first four tax years of trade, losses are restricted to the lower of: £25,000 per year; and. The partner’s capital contributions at the end of the basis period for the relevant tax year, less any relief previouslyclaimed.
THOMAS WEST
Thomas is a general client partner providing a full range of compliance and advisory services to individuals and families, and their businesses, trusts and charities. His practice has a particular focus on landed estates, with clients including traditional large country estates, valuable urban commercial portfolios and property investment and development companies. CORPORATE INTEREST EXPENSE The worldwide debt cap rules were repealed effective from 1 April 2017 and have been replaced by the new corporate interest expense rules. The motivation behind the new rules is to restrict the amount of tax relief for interest expenditure claimed by large or multinational groups that are highly leveraged.STEPHAN HARTRY
Stephan Hartry. Stephan is a private client tax director providing a full range of tax advisory and compliance services to individuals, their trusts, charities and businesses. Stephan has almost 15 years’ experience advising on all aspects of UK taxation. His work focuses particularly on non-UK domiciled individuals, international taxation Skip to main contentMAIN NAVIGATION
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