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Andrew Gotch

ANDREW GOTCH and HUI LING MCCARTHY consider the future of HMRC’s alternative dispute resolution project
ANDREW GOTCH offers advice to practitioners on how not to get caught out by the adverse conditions of HMRC's new powers
Reviewed by ANDREW GOTCH BA, MA, CTA (Fellow), principal of TaxFellowship, Chartered Tax Advisers, and a senior consultant to IRIS Professional Tax Practice (
Operating the new construction industry scheme is not going to be easy, warns ANDREW GOTCH.

A Brief Opportunity


ANDREW GOTCH highlights a mismatch in the loan relationship provisions.


COMPANY A HAS a 50 per cent interest in company B. Company A has made funding loans to company B in the past and these are irrecoverable. Company A accounts to 30 September; company B accounts to 31 March. Both companies are close. If company A releases the loan, what are the tax consequences?


Two capital gains tax reliefs have been surreptitiously curtailed, warns ANDREW GOTCH.

IN 6 APRIL 2003 two significant planning tools will suffer a change for the worse. This is a trap that has been in place since 1998, and many advisers will have forgotten that its jaws are slowly closing. In addition, new legislation in the Finance Act 2002 has had an adverse impact on a related area of more specialist interest.


Holdover relief


In the 'Loose Ends' of Taxation, 25 October 2001, Nick Lloyd mentioned the new bureaucracy brought about by the Inland Revenue requirement to make returns under section 16, Taxes Management Act 1970.
ANDREW GOTCH, consultant for Professional Tax Practice Ltd, scrutinises the House of Lords' decision in R v Commissioners of Inland Revenue ex parte Newfields Developments Ltd.
ANDREW GOTCH, consultant for Professional Tax Practice Ltd, suggests an area ripe for consideration in the Revenue's review of the interaction of taper relief with loan notes
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