A round up of other news this week.
In Stephen Warshaw v HMRC, the First-tier Tribunal has concluded that cumulative compounding preference shares are Ordinary Share Capital (OSC). As a result, the company was the taxpayer’s ‘personal company’ and he qualified for Entrepreneurs’ Relief on the gain on disposal.
The taxpayer has been refused permission to appeal to the Supreme Court, making the Court of Appeal decision final in the case of GDF Suez Teeside Limited v HMRC. The case considered a disclosed arrangement involving the transfer of loan relationship assets in exchange for the issue of shares. The taxpayer was required to recognise a taxable profit equal to the fair value of the transferred assets because this ‘fairly represents’ the profit from the transfers of loan relationship assets. While the ‘fairly represents’ legislation ceased to apply for periods beginning on or after 1 January 2016, the decision may still be relevant to open enquiries for earlier periods. If you would like further information on the implications for your business, please speak to your usual contact.
Optimism in the UK technology sector dropped to a ten-year low in Q1, despite business activity growth recovering to its fastest pace since Q2 of last year, according to the latest quarterly survey of UK technology sector companies by KPMG.
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