Corporate residence can be a problematic area. A company may be resident overseas if it can show that its central management and control takes place outside the UK, but if a company only carries out a few transactions (such as the purchase or sale of subsidiaries), what level of involvement is needed to exhibit central management and control?
THE SECOND ARTICLE of this series of two, looks at the changes to the operation of capital gains tax only or main residence relief made in the FA 2004 in response to what the Government perceived as unacceptable tax planning. (All references are to the Taxation of Chargeable Gains Act 1992, unless otherwise stated.)
PARTS OF THE tax legislation remind me of my first car. The vehicle was fairly old, but it ran reasonably well on the whole. However, not having much money to spend in those days on car repairs and such like, it was often a case of 'patch up and make do'. Unfortunately, this strategy did not always work, and the repair bill often seemed out of proportion to the original breakdown.
Taper Relief
A Substantial Qualification
PAUL HODGE and MATT REID explain that the effect of a company's activities on entitlement to business asset taper relief is not at all straightforward!
Domicile
Domicile On Hold
TIM KEELEY provides a guide to the remittance basis.