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Companies

AMANDA FLINT looks at transfer pricing and share schemes.

KEITH GORDON ACA, CTA, barrister argues that unintended changes to the tax law made by Rewrite Bills should be amended in future Finance Bills.

MICHAEL TUHME warns practitioners not to be caught out by unexpected problems with loans to participators

From time to time I have the pleasure of putting my corporation tax commitments to one side and working instead alongside our corporate finance team in carrying out tax due diligence reviews, principally assisting banks with their investment decisions in private company acquisitions.

BRIAN LAWLESS is not convinced by Ruth Kelly's reassurances on pensions for shareholder directors
GARRY HUGHES reviews the House of Lords' decision in MacDonald v Dextra.

RICHARD CURTIS reviews the decision in B E Studios Ltd v Smith & Williamson Ltd.

B E STUDIOS LTD (BES) was incorporated in June 1999 to specialise in the design, production and sale of software for computer games and other commercial uses. After starting on a relatively small scale it started to recruit staff and this process was complete by June 2000. In October 2000, the company retained chartered accountants, Smith & Williamson Ltd, (S & W) to provide tax, financial planning and accountancy advice.

WYN HUGHES and ANDY MAXFIELD consider the tax advantages of Isle of Man corporations.


THE ISLE OF Man has long been considered an ideal location to site an offshore corporate base. Situated in the Irish Sea, within easy reach of the United Kingdom and Ireland, and using pound sterling as the principal unit of currency, the professional and financial services sector on the island is booming, with many non-Manx residents establishing Manx companies to their advantage.

RICHARD CURTIS drills into the tax implications of the Shell and Royal Dutch Petroleum merger.

MIKE TRUMAN looks at the High Court judgment in Small (HMIT) v Mars UK Ltd, and asks what it means for the Distillers case.


MALCOLM GUNN FTII, TEP examines a controversial Revenue statement on termination payments.

IN 1991, THE Revenue issued a statement of practice which was part of its 'Mystifying Misinterpretations' series for practitioners. As readers may know, there is a companion set of publications, the 'Catastrophic Climbdowns' series, which is much smaller and includes the Revenue statement following the decision in Mansworth v Jelley [2003] STC 53, and another one from some years ago concerning insurance commission rebates.

JOHN WOSNER reviews the underlying principles of the Jones v Garnett — 'Arctic Systems' — case.

ROBERT MAAS FCA, FTII explains why he thinks that UITF 40 does not have much impact on work in progress.

SITTING ON THE fence was how I concluded my article, 'WIP RIP?', Taxation 5 May 2005, page 117 on the impact of Urgent Issues Taskforce (UITF) 40, but I promised to think further. I am now firmly of the view that work in progress is alive and well and that UITF 40 has not changed very much. I am conscious that this seems to be a minority view, so it seems sensible to explain my reasoning.

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