Weil Tax BLOG - Feed https://tax.weil.com/category/uk-tax/capital-gains/ Views and developments from the Tax Department at Weil Tue, 05 May 2026 15:19:09 +0000 hourly 1 Summer in the City: Draft UK Tax Legislation Published on 6 July 2018 https://tax.weil.com/uk-tax/corporation-tax/summer-in-the-city-draft-uk-tax-legislation-published-on-6-july-2018/ Fri, 13 Jul 2018 14:03:06 +0000 Stuart Pibworth http://tax.weil.com/?p=499 On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

The post Summer in the City: Draft UK Tax Legislation Published on 6 July 2018 appeared first on Weil Tax BLOG.

]]> On 6 July 2018 the UK government published draft legislation expected to form the Finance Bill 2019 (the “Draft Legislation”), together with accompanying explanatory notes, tax information and impact notes and other ancillary documentation.  Publishing the Draft Legislation in the Summer, months before the introduction of the next Finance Bill, forms part of the Government’s

The post Summer in the City: Draft UK Tax Legislation Published on 6 July 2018 appeared first on Weil Tax BLOG.

]]> QCBs and the Limits of Purposive Interpretation https://tax.weil.com/uk-tax/qcb/qcbs-and-the-limits-of-purposive-interpretation/ Wed, 17 Jan 2018 16:02:26 +0000 Oliver Walker http://tax.weil.com/?p=488 The Court of Appeal has unanimously held that terms which convert the currency of bonds from sterling to the Euro (and which also allowed the bonds to be repaid in Euros) following an adoption by the UK of the Euro did not preclude the bonds from constituting “qualifying corporate bonds” (“QCBs”).  While at first glance

The post QCBs and the Limits of Purposive Interpretation appeared first on Weil Tax BLOG.

]]> The Court of Appeal has unanimously held that terms which convert the currency of bonds from sterling to the Euro (and which also allowed the bonds to be repaid in Euros) following an adoption by the UK of the Euro did not preclude the bonds from constituting “qualifying corporate bonds” (“QCBs”).  While at first glance

The post QCBs and the Limits of Purposive Interpretation appeared first on Weil Tax BLOG.

]]> Section 27: Substantial Shareholding Exemption; Section 28: Substantial Shareholding Exemption: Institutional Investors https://tax.weil.com/uk-tax/section-27-substantial-shareholding-exemption-section-28-substantial-shareholding-exemption-institutional-investors/ Fri, 08 Dec 2017 14:04:35 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=485 Where certain requirements are met, the UK substantial shareholding exemption (the SSE) has the effect of automatically exempting any gain (or disallowing any loss) arising on the disposal of shareholdings from the scope of UK corporation tax on chargeable gains. Since the introduction of the SSE by the UK Government (the Government) in April 2002,

The post Section 27: Substantial Shareholding Exemption; Section 28: Substantial Shareholding Exemption: Institutional Investors appeared first on Weil Tax BLOG.

]]> Where certain requirements are met, the UK substantial shareholding exemption (the SSE) has the effect of automatically exempting any gain (or disallowing any loss) arising on the disposal of shareholdings from the scope of UK corporation tax on chargeable gains. Since the introduction of the SSE by the UK Government (the Government) in April 2002,

The post Section 27: Substantial Shareholding Exemption; Section 28: Substantial Shareholding Exemption: Institutional Investors appeared first on Weil Tax BLOG.

]]> Ordinary Share Capital: Clarity in Relation to Dividend Rights https://tax.weil.com/uk-tax/uk-focus-latest-thinking/ordinary-share-capital-clarity-in-relation-to-dividend-rights/ Sun, 01 Oct 2017 17:10:06 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=483 The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

The post Ordinary Share Capital: Clarity in Relation to Dividend Rights appeared first on Weil Tax BLOG.

]]> The Upper Tribunal has overturned the decision of the First-tier Tribunal in McQuillan v HMRC, finding that non-dividend bearing redeemable shares constituted ordinary share capital for the purposes of section 989 of the Income Tax Act 2007 (section 989) ([2017] UKUT 344 (TCC)) (see Focus “Ordinary share capital: can a negative prove a positive?”, www.practicallaw.com/2-631-2725).

The post Ordinary Share Capital: Clarity in Relation to Dividend Rights appeared first on Weil Tax BLOG.

]]> Weil on the Move – Episode 1 – The New SSE: Good for Geese and Ganders? https://tax.weil.com/uk-tax/straight-to-the-point/weil-on-the-move-episode-1-the-new-sse-good-for-geese-and-ganders/ Tue, 11 Apr 2017 14:22:10 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=475 In Autumn 2016, the U.K. Government announced that the domestic exemption from U.K. corporation tax on gains arising on the disposal of substantial shareholdings, known as the “substantial shareholdings exemption” or “SSE”, would be reformed. Since that announcement, the government has consulted on the potential changes, and has published draft legislation which was expected to

The post Weil on the Move – Episode 1 – The New SSE: Good for Geese and Ganders? appeared first on Weil Tax BLOG.

]]> In Autumn 2016, the U.K. Government announced that the domestic exemption from U.K. corporation tax on gains arising on the disposal of substantial shareholdings, known as the “substantial shareholdings exemption” or “SSE”, would be reformed. Since that announcement, the government has consulted on the potential changes, and has published draft legislation which was expected to

The post Weil on the Move – Episode 1 – The New SSE: Good for Geese and Ganders? appeared first on Weil Tax BLOG.

]]> Reform of the Substantial Shareholdings Exemption https://tax.weil.com/uk-tax/uk-focus-latest-thinking/reform-of-the-substantial-shareholdings-exemption/ Tue, 17 Jan 2017 10:54:45 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=471 Although the principal considerations for the structuring of global business operations and investments usually focus on commercial and operational factors, such considerations are not looked at in a vacuum. Invariably, the financial modelling of any investment structure will also take into account the tax cost of profit extraction and exit. Read more.

The post Reform of the Substantial Shareholdings Exemption appeared first on Weil Tax BLOG.

]]> Although the principal considerations for the structuring of global business operations and investments usually focus on commercial and operational factors, such considerations are not looked at in a vacuum. Invariably, the financial modelling of any investment structure will also take into account the tax cost of profit extraction and exit. Read more.

The post Reform of the Substantial Shareholdings Exemption appeared first on Weil Tax BLOG.

]]> Reforming the Substantial Shareholdings Exemption: Keeping Up with the Joneses https://tax.weil.com/uk-tax/straight-to-the-point/reforming-the-substantial-shareholdings-exemption-keeping-up-with-the-joneses/ Thu, 05 Jan 2017 16:58:52 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=470 Following the government’s announcement in the 2016 Autumn Statement that the substantial shareholdings exemption (SSE) would be reformed, draft legislation to implement the reform was published on 5 December 2016. Read more.

The post Reforming the Substantial Shareholdings Exemption: Keeping Up with the Joneses appeared first on Weil Tax BLOG.

]]> Following the government’s announcement in the 2016 Autumn Statement that the substantial shareholdings exemption (SSE) would be reformed, draft legislation to implement the reform was published on 5 December 2016. Read more.

The post Reforming the Substantial Shareholdings Exemption: Keeping Up with the Joneses appeared first on Weil Tax BLOG.

]]> Ordinary Share Capital: Can a Negative Prove a Positive? https://tax.weil.com/uk-tax/straight-to-the-point/ordinary-share-capital-can-a-negative-prove-a-positive/ Wed, 17 Aug 2016 12:50:08 +0000 Oliver Walker Stuart Pibworth http://tax.weil.com/?p=465 The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

The post Ordinary Share Capital: Can a Negative Prove a Positive? appeared first on Weil Tax BLOG.

]]> The recent decision in McQuillan v HMRC highlights the challenges faced by taxpayers seeking to apply correctly those parts of the UK tax code that require interpretation in the absence of conclusive definition ([2016] UKFTT 305 (TC)). McQuillan addresses whether shares with no dividend rights can be said to carry a fixed rate of dividend

The post Ordinary Share Capital: Can a Negative Prove a Positive? appeared first on Weil Tax BLOG.

]]>