LONSDALE V BRAISBY was recently heard in the Court of Appeal following decisions from the High Court ([2004] STC 1606) and the General Commissioners. The points at issue were the amount of unused relief relating to retirement annuity plans and how the sum of unused relief is calculated and reduced under the transitional provisions of TA 1988, s 655(1).
TONY BLAIR FAMOUSLY referred to 'education, education, education'. For this third Labour administration, the phrase 'pensions, pensions, pensions' is probably more appropriate. However, there is a link with education and that is as far as the pensions knowledge of tax advisers is concerned.
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.
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.

