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.
AS THE PAGES of Taxation magazine have testified over the years, the taxation of companies repurchasing their own shares — while deceptively straightforward — is often fraught with difficulties. Most such problems seem to be caused by an incomplete understanding of the company law issues involved in a share repurchase and the effect that these can have on the tax treatment.
A VALUABLE RELIEF for companies which provide shares for employees was introduced by FA 2003, Sch 23 and this article examines the background to that schedule and also explores the conditions that have to be satisfied in order to claim the relief.

