UK Tax Podcast

Send us Fan Mail In this episode of The UK Tax Podcast, Chartered Tax Adviser John Kavanagh explains the tax treatment of corporate demergers under UK law, focusing on the three principal routes: statutory demergers, capital reduction demergers, and reconstructions by liquidation. Designed for non-specialist advisers, the episode sets out the conditions for each type of demerger, identifies key ta...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh looks at some of the most common errors made when applying the Statutory Residence Test. He explains the correct order in which the automatic overseas, automatic UK, and sufficient ties tests must be applied, and highlights frequent mistakes in interpreting UK days, transit days, and UK workdays. The episode also covers common m...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh explores the rules for claiming mixed-use treatment on property purchases for SDLT purposes. He examines recent tribunal decisions, including Ridgway, Tretyakov, and Suterwalla, and considers how the courts have interpreted residential versus non-residential use at the time of completion. The episode highlights HMRC’s increasing...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh explains the essentials of Enterprise Management Incentive (EMI) options, a highly tax-efficient way for smaller businesses to attract and retain key employees. He covers the qualifying conditions, tax advantages, and planning points, with a particular focus on the recent changes to Business Asset Disposal Relief (BADR) rates. F...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh examines the rules regarding UK corporate tax residenceand the approach taken by HMRC. He explains the UK’s central management and control test, how HMRC has challenged offshore structures, and the role of double tax treaties in resolving residence disputes. The episode also explores the growing use of the mutual agreement proce...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a...

Send us Fan Mail In this episode of The UK Tax Podcast, John Kavanagh explores a significant recent decision from the Court of Appeal in the case of A Taxpayer v HMRC. The case considers how the Statutory Residence Test (SRT) deals with exceptional circumstances and when a taxpayer can be considered prevented from leaving the UK due to unforeseen personal events. The facts involve a taxpayer who e...

Send us Fan Mail In this episode of the UK Tax Podcast, Chartered Tax Adviser John Kavanagh explores the tax implications of divorce settlements, including the Capital Gains Tax consequences of asset transfers, the Stamp Duty Land Tax implications of transfers of equity, and key Inheritance Tax considerations once a marriage or civil partnership ends. With practical insights and clear explanations...

Send us Fan Mail In this episode of the UK Tax Podcast, Chartered Tax Adviser John Kavanagh examines the process of incorporating a property portfolio held by a partnership or LLP into a limited company. John explains the potential tax advantages, including Capital Gains Tax and Stamp Duty Land Tax reliefs, as well as the key risks around mortgage debt, novation, and HMRC’s evolving position on in...

Send us Fan Mail In this episode of the UK Tax Podcast, Chartered Tax Adviser John Kavanagh discusses the sweeping changes to Inheritance Tax (IHT) announced in the Autumn Budget 2024. From the abolition of domicile as a factor for IHT from April 2025, to the extension of IHT to unused pension funds and the capping of Business and Agricultural Property Relief, these changes represent the most sign...

Send us Fan Mail In this episode of the UK Tax Podcast, Chartered Tax Adviser John Kavanagh takes an in-depth look at Employee Ownership Trusts (EOTs), with a particular focus on the significant changes introduced in the October 2024 Budget. John explains how EOTs work, the tax benefits they can offer, and the compliance challenges that sellers now face, including the extended Capital Gains Tax cl...