Corporate and Business Tax
Temple Tax has recognised specialists in corporate and business tax who are expert in the technical requirements of the legislation and also closely attuned to commercial reality and client needs. Members advise on all aspects of business tax from general advice and structuring to drafting agreements and clearance applications or disclosures to HMRC. Recent matters on which members have advise include:
- SPAs: maximising ER, earn-outs, differential consideration and Part 7 of ITEPA; issues arising on due diligence and warranties and indemnities.
- Purchases of own shares including payments in instalments and application of the market value rule.
- EIS including satisfying the conditions, returns of value and risk to capital.
- ER including the 5% test post-FA 2019, meaning of “ordinary share capital”, dilution relief, dilution on day of sale and maximising ER on earn-outs.
- Non-residents holding UK property/property-rich companies and the NRCG.
- Employee ownership trusts, including structuring corporate funding.
- Transaction in Securities provisions on returns of capital, retained interests following a buy-out, the scope of the section 686 safe haven and partitioning jointly held companies
- Partnerships and LLPs including corporate partners post sections 850C-E ITTOIA, ER and IHT BPR.
- Corporate debt and the loan relationship provisions.
- Intra-group transfers of assets including intangibles.
- Loss relief rules.
- Business and partnership incorporations, rollover relief (s.162), issues concerning goodwill.