Company Tax planning
Company
Reorganisation
Company A Limited owned an asset worth a substantial amount. The asset was in a company in which the owners were involved in entrepreneurial ventures. The directors were looking to continue with their speculative business ventures yet wanted to protect the asset from the commercial risk.
Comment: Shipleys Tax undertook a group reconstruction which resulted in the asset being transferred to another entity without any immediate tax liability to the company or its shareholders.
Partial Sale
Company X Group Limited was looking to sell off two subsidiaries to a buyer in exchange for shares. With the structure the client had in place, the sale of the two companies would have resulted in a tax liability of around £1.8 million on a paper gain and also caused the shareholders to lose favoured tax status.
Comment: Shipleys devised a group reorganisation which resulted in the two companies being sold with no immediate tax liability to the group or its shareholders.
Share schemes
Company Y Limited wished to reward and tie in employees. Bonus schemes were expensive and arbitrary and caused cash constraints.
Comment: Shipleys implemented a tax efficient share scheme arrangement. This achieved the client’s objectives and also gave the founder shareholders the opportunity to establish an alternative exit strategy.
Parallel companies
Company A Limited had a very complex company structure comprising of a number of non-trading intermediate holding and parallel companies which served no particular purpose and was not a tax efficient structure. The structure had arisen as a result of a piecemeal acquisitions and shareholder changes which was administratively difficult to manage. The parallel companies were related and had numerous inter company loans which the directors wanted to make tax efficient.
Comment: Shipleys implemented a tax efficient group reorganisation and put measures into place which would enable them to take full control of their inter company loans with minimal tax consequences.
Latest news & blogs…
Mini-Budget scrapped by new Chancellor
THE NEW CHANCELLOR has today scrapped most of the mini-Budget announcements made by his short lived predecessor. What, if any, of the announcements made by Kwasi Kwarteng survived the latest round of U-turns?
In today’s brief Shipleys Tax blog, we look at the latest round of fiscal policy announcements, which may or may not stick around.
What’s left from the mini-Budget 2022
The Chancellor, Jeremy Hunt, announced today that the cutting of the basic rate of income tax (from 20% to 19%) would be postponed indefinitely – at least until “economic conditions allow a reduction”.
This had been rumoured toward the end of last week, but that wasn’t the end of the U-turns. The planned cutting of dividend tax (which was increased in line with National Insurance) has also been scrapped, as has the reversal of the controversial off-payroll working/IR35 rules. The cap on energy bills that was set to last for two years will now, however, be reassessed in April.
What has remained?
The only major measures that remain from the mini-Budget are the changes to National Insurance (1.25% cut retained), increase in the stamp duty land tax allowance, and the permanent increase of the annual investment allowance to £1 million.
More to follow.
Further embarassing U-turns on the Mini-budget 2022
THE EMBARASSING farce continues at Westminster with more twist and turns than reality TV. The PM Liz Truss has today overseen more U-turns to her now defunct flagship fiscal policy – the Mini-BUdget 2022.
Here at Shipleys Tax we look at the new merry-go-round of announcements made today. Quite how long these policies will last is anyone’s guess.
NEW Summary Budget measures – 14 October 2022
- Income tax
45% Additional rate abolished (40% top rate now)SCRAPPED – 45% top tax rate to be reinstated- Basic rate cut to 19% (from 20%) – RETAINED FOR NOW
- NIC – April 2022 increase in NIC reversed from 6 November and Health & Social Care Levy scrapped: RETAINED
Corporation tax to remain at 19% – planned 2023 increase to 25% cancelledSCRAPPED – Rise to 25% reinstated- Off payroll working/IR35 – previous legislative changes to be repealed from April 2023 – RETAINED
- Introduction of VAT-free shopping for overseas visitors – RETAINED
- New “Investment Zones” with enhanced tax reliefs and relaxed planning frameworks – RETAINED
- Removal of cap on bankers’ bonuses – – RETAINED
- SEIS and CSOP limits to be increased. EIS and VCT reliefs will be extended beyond 2025 – RETAINED
- Annual Investment Allowance to stay at £1m for capital allowances – RETAINED
- No stamp duty on first £250,000, for first time buyers that rises to £425,000 – comes into operation today- RETAINED
All policies subject to change. Further detail to follow.
U-turn by Chancellor on 45p Tax Rate
AFTER A DRAMATIC U-turn the Chancellor has decided to scrap the 45% tax rate. The move was widely criticised amid a cost-of-living and energy crisis and has gathered hugely negative momentum over the course of a few days.
At Shipleys Tax we have the latest on the mini-budget merry go round.
Turning point…
The Chancellor has confirmed that the tax cut will not go ahead, due to the distractions this policy has caused, reversing the announcement only made a few days ago to a lot of fanfare.
Now, from 6 April 2023 those earning over £150,000 will continue to pay the top rate of 45% income tax. However, due to other planned tax cuts, those with income over £150,000 will pay just 38.1% income tax on dividends from 6 April 2023 (currently 39.35%), meaning there will still be an incentive (albeit a smaller one) to delay dividends until on or after 6 April 2023.
The Chancellor is set to announce his medium-term fiscal plan on 23 November.
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