Milk quota and a 'fungible' asset
It is understood that the Revenue takes the not unreasonable view that milk quota is a fungible asset. It is worth considering what benefit this could have to the farmer.
When corporation tax self assessment was introduced with effect from 1 July 1999, it adopted many of the provisions that existed under corporation tax pay and file.
Reverse VAT confusion
Paragraphs 16 and 23 of Schedule 13 to the Finance Act 1999 create events requiring documents to be stamped £5 in circumstances in which 'reverse' consideration is given. Practitioners will be familiar with this concept in a VAT context, but may perhaps not have given too much thought to the stamp duty position.
THE AGGREGATES LEVY was the main feature of Finance Act 2001. The postponement of the General Election as a result of the foot and mouth crisis led to the Bill being 'debated' under a Government guillotine imposed from the outset. The controversial nature of the new tax meant that the Opposition parties had to devote almost all the time allocated to questioning the environmental case for and the economic consequences of the imposition of this tax from next April.
A partnership may be run alongside a company, sometimes as a means of mitigating National Insurance contributions. The chickens can, however, come home to roost with a vengeance on a sale of the shares in the company. The Revenue will often argue that the existence of the partnership means that the director is not a full-time working director of the company and that therefore retirement relief is not due.
One of the main advantages of options under the enterprise management incentive scheme is that taper relief starts running from the date the option is granted, not the date the option is exercised. It has often been the practice with, for example, shares acquired under an executive share option scheme (what the Revenue now calls a CSOP) to transfer shares to a spouse to use capital gains tax exemptions efficiently. Does this work with shares acquired under an enterprise management scheme option?
One of the main advantages of options under the enterprise management incentive scheme is that taper relief starts running from the date the option is granted, not the date the option is exercised. It has often been the practice with, for example, shares acquired under an executive share option scheme (what the Revenue now calls a CSOP) to transfer shares to a spouse to use capital gains tax exemptions efficiently. Does this work with shares acquired under an enterprise management scheme option?
Loose Ends
VAT and conveyancing: when is the tax point?
Under the English system of conveyancing, the deposit is usually paid to the vendor's solicitors as stakeholders at exchange of contracts and released on completion when vacant possession is given against payment of the balance of the purchase price. This gives rise to no problem as far as VAT is concerned, because both payment and the 'making available' of the 'goods' constitute events of charge under, respectively, section 6(4) and 6(2)(b) of the VAT Act 1994.
Secondary liability for landfill tax