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.
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.
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.
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.
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.

