Key points
- HMRC’s use of the transactions in securities rules.
- The structures and buildings allowance has its own definition of ‘residential’.
- The taxation of termination payments.
- From April 2020 non-resident corporate landlords will be subject to corporation tax on UK lettings.
- Payment of stamp duty proves title to an asset.
- Advisers are making fundamental mistakes when claiming research and development tax relief.
- Satisfactory progress on Making Tax Digital for VAT.
Transactions in securities
Pete Miller introduced the history of the transactions in securities (TIS) legislation (ITA 2007 Part 13 ch 1) demonstrating how converting income into capital to save tax has always been an issue the government tries to combat. He explained the subtle changes with ITA 2007 s 684 before and after 6 April 2016 highlighting that the TIS rules can now be used to counteract an income tax advantage arising to any person not just a person who...
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