New owner-employees- no CGT but no employment rights either…
HM Treasury has today published a press release on a new type of employee share scheme. The hybrid scheme is actually proposed to be a new kind of employment contract called an owner-employee, available from April 2013. New owner-employees will exchange some of their UK employment rights for rights of ownership in the form of shares in the business they […]
Before the Budget #Budget2012
Well, it is nearly upon us, Budget 2012. So far we are expecting the 50p tax rate to go down to 45p from April 2013, the personal allowance to go up to £9,205 from the same date, and everyone in the middle, inclduing those losing child benefit, to pay for it all. Let’s wait and see…
Plumbers are next on HMRC’s hit list
After Doctors, Dentists and offshore bank account holders, now Plumbers are the latest quarry in HMRC’s sights. The brand new Plumbers Tax Safe Plan (PTSP) is here and out to get plumbers, gas fitters and heating engineers the length and breadth of the country. Of course, HMRC don’t sell it that they are out to get you scurrilous and dishonest […]
Can you get negligible value relief where the shares are sham shares?
The exact wording of section 24(2) TCGA 1992 refers to making a claim (for negligible value) where “the value of an asset has become negligible”. HMRC manuals (at CG13118) emphasise the wording of the law thus: “The owner of an asset which has BECOME (see CG13133) of negligible value may claim to have the asset treated as though it had […]
Deja- vu on residence?
There has been much activity over the last couple of years in respect of the merry go round that UK residence, or non-residence, is proving to be. Most people will have heard of Robert Gaines-Cooper and his ongoing trawl through the courts, but there have also been a number of other confusing and contradictory cases regarding UK residence and ordinary […]