Company reconstructions – liabilities restriction
The rules for the Corporation Tax treatment of carried forward losses changed from 1 April 2017. The changes increased flexibility to set off carried forward losses against total profits of the same company or another company in a group whilst at the same time introducing new restrictions as to the amount of profits against which carried forward losses can be set.
However, there is a specific restriction in respect of company reconstructions that disallows carried forward losses to a successor
HMRC “sweetheart” deals
HMRC has issued an interesting press release stating that ‘Fact: HMRC does not do ‘sweetheart deals’. HMRC makes sure every taxpayer, no matter what their size, pays everything they owe.’
This denial could be in response to many claims that have been made over the years in Parliament and the press suggesting that HMRC offers better settlement terms when dealing with certain taxpayers (usually the largest UK businesses and multinationals). HMRC refutes these claims saying they seek to collect
Global minimum Corporation Tax of 15%
A new consultation has been published by the UK government seeking views for how a worldwide 15% minimum Corporation Tax should be enforced domestically. This follows more than 130 countries signing up to a new global minimum tax framework in October 2021, after the G7 agreed in principle to this measure during UK’s presidency.
We have also seen publication of the Global Anti-Base Erosion Model Rules (Pillar Two) by the OECD/ G20 on 20 December 2021. This paper states that implementation of
Replacement of domestic items in let property
The replacement of domestic items relief has been in place since April 2016. The relief allows landlords to claim tax relief when they replace movable furniture, furnishings, household appliances and kitchenware in a rental property. The allowance is available for the cost of domestic items such as free-standing wardrobes, curtains, carpets, televisions, fridges and crockery.
The amount of the deduction is based on:
the cost of the new replacement item, limited to the cost of an equivalent
Tax relief for working from home
If you are an employee working from home, you may be able to claim tax relief for some of the bills you pay that are related to your work.
Employers can reimburse employees for the additional household expenses incurred through regularly working at home.
The relief covers expenses such as business telephone calls or heating and lighting costs for the room you are working in. Expenses that are for private and business use (such as broadband) cannot be claimed. Employees may also be able to
Leaving gifts to charity in your Will
The government introduced new rules to encourage charitable giving on death in 2012. The rule which has remained unchanged ever since means that a reduced rate of Inheritance Tax (IHT) of 36% (reduced from 40%) applies where 10% or more of a deceased’s net estate is left to charity. The lower rate applies where 10% or more of the ‘net value’ of the estate is left to charity.
The current IHT nil rate band is £325,000 per person, below which no Inheritance Tax is payable. Any unused nil rate band