NOTES

Question 1

CT: Dispose of shares?

Answer 1

“TEN PERCENT, TRADING and TWELVE MONTHS (last 6y)?

-> SSE!!”

Question 2

CT losses: What are TRADING loss reliefs against?

Answer 2

ALL TRADE CT LOSSES are relieved against TOTAL PROFITS

Question 3

Consortium

Answer 3

“Up to 20 members
Each 5%
Control
Max 75% (otherwise 75% group!)”

Question 4

CT: what’s the max loss you can relieve?

Answer 4

“Deductions allowance: FIVE MILLION PLUS HALF PROFITS
(One per group & for 12m)”

Question 5

Terminal loss relief timings: Main loss? B/f losses left?

Answer 5

“Main TLR: 36m from START of period
B/F losses left? 36m from END of period (LIFO) (& not before loss occurred aha)”

Question 6

Pensions summary

Answer 6

“Employer: Deduct from TTP

Employee:
Occupational: Deducted via PAYE
Personal: Extent bands by BR amount”

Question 7

Disposing of business assets?

Answer 7

“TRADING assets owned TWO YEARS
Shares? Own FIVE PERCENT and EMPLOYEE
-> BADR”

Question 8

MCIOCT

Answer 8

“Control and change in trade in FIVE YEARS? LOSSES RINGFENCED
(Eight years for non-trade losses)”

Question 9

Gains group

Answer 9

“75% direct, 50% indirect
Can only be in one
Non res links but not in group

Benefit: NGNL & SSE
But: Degrouping charge”

Question 10

Corp tax: Goodwill/IFAs basic treatment

Answer 10

“6.5% cost capped at 6x value
No ROR on amortization”

Question 11

Surrendering b/f loss in a loss group?

Answer 11

HAVE TO CLAIM MAXIMUM YOURSELF FIRST

Question 12

What to think about when claiming lots of losses?

Answer 12

“There is a DEDUCTIONS ALLOWANCE

ONE PER GROUP!”

Question 13

What do you have to do if surrendering losses in a group with difference accounting periods?

Answer 13

You CAN, but have to TIME APPORTION

Question 14

Corp tax R&D benefit

Answer 14

“SME: Extra 86% deduction
Large: 20% tax credit”

Question 15

Loss groups

Answer 15

“Strict 75%
Can be in multiple”

Question 16

Employee remuneration: Termination payments

Answer 16

“Shock? (Death) ALL TAX FREE

Expected? ALL TAXABLE

Surprise?
Statutory redundancy: All exempt but reduces 30k limit
Discretionary: Up to 30k limit tax free then top-sliced afterwards
Pension/retrain/counselling/outpatient: Exempt (benefits)
PILON: Pro rate between normal income and termination rules”

Question 17

Do you get BADR on transfer of goodwill?

Answer 17

“Goodwill transferred to close company where you own 5%? (Normally incorporation!)
-> NO BADR!

(Unless sell to unconnected person in 28d)”

Question 18

What NICs do employers pay for employees?

Answer 18

“Class 1 secondary (salary)
1A (benefits)
1B (PAYE settlement)”

Question 19

What NICs do employees pay?

Answer 19

Class 1 primary

Question 20

What NICs do self employed people pay?

Answer 20

“Class 2 (flat rate)
Class 4 (profits)”

Question 21

What’s the difference with a non tax-advantaged share scheme?

Answer 21

Also pay INCOME TAX when BUYING the shares

Question 22

When can you claim BADR on EMI shares?

Answer 22

2y from GRANT and NO PERCENTAGE HOLDING

Question 23

What benefit do companies get with tax advantaged schemes?

Answer 23

They can deduct the DISCOUNT GIVEN to the employee

Question 24

General approach for income tax if uk res but not uk domicile?

Answer 24

Non UK income taxed on remittance basis (otherwise deemed domicile)

Question 25

Overseas VAT: Treatment of EXPORTS

Answer 25

ZERO RATED

Question 26

Overseas VAT: Treatment of IMPORTS

Answer 26

“Pay VAT at POINT OF ENTRY
VAT reg bus? Can choose POSTPONED ACCOUNTING”

Question 27

Overseas VAT: Treatment if SUPPLY SERVICES

Answer 27

“Customer not business? VAT (place of supply = supplier)
Customer a business? NO VAT (place of supply - bus)
Land? Where land is
“

Question 28

Overseas VAT: RECEIVE SERVICES?

Answer 28

“NO VAT
But REVERSE CHARGE”

Question 29

Individuals property interest treatment?

Answer 29

“Taxable, THEN 20% REDUCER
If buy to let, then cap on the reducer”

Question 30

Company making large profit from developing residential property?

Answer 30

Over 25m? May be RPDT

Question 31

Capital loss on shares?

Answer 31

“Unquoted trading or EIS?
Then SHARE LOSS RELIEF
-> Offset current/prior net income”

Question 32

Capital losses with connected person?

Answer 32

Can only relieve with the SAME CONNECTED PERSON

Question 33

How is the write off of a close company loan treated?

Answer 33

As a DIVIDEND

Question 34

What happens when you migrate a company overseas?

Answer 34

“EXIT CHARGE
Assume all (non PE) assets sold”

Question 35

IHT: Is settled property a trust? Who pays?

Answer 35

“Trust
Trustees pay”

Question 36

IHT: Is free estate a trust? Who pays?

Answer 36

“Not a trust
Representatives pay”

Question 37

IHT: Property and spouses: Joint tenants

Answer 37

Passes to spouse

Question 38

IHT: Property and spouses: Tenants in common?

Answer 38

Separate defined shares

Question 39

IHT: Downsizing allowance

Answer 39

“Downsized after (8 Jul) 2015 and WOULD HAVE HAD RNRB and leave something to direct descendants still?
You get RNRB lost (capped at what given to direct descendants)

Question 40

IHT: BPR

Answer 40

“TRADING business property held TWO YEARS?
100% relief for sole trader bus, share in pship, UNQUOTED SHARES, some hol accom
50% relief for QUOTED SHARES WITH CONTROL and p&m in pship/comp with control”

Question 41

IHT: What might apply if GWROB doesn’t?

Answer 41

Pre-Owned Asset Tax

Question 42

What to also remember when there is a gain on a CLT?

Answer 42

You also get gift relief (as well as IHT)