In this episode, Nick Wright, Head of Corporate Tax and Host of ‘The Tax Hour’ is joined by Michael Sherry, Tax Counsel at Temple Tax Chambers. In this episode Michael and Nick discuss Anti-Avoidance rules within the tax system and consider recent HMRC Spotlights.

Anti-Avoidance refers to the framework of rules and principles designed to counteract tax arrangements that, while technically legal, are structured primarily to achieve a tax benefit in a way that undermines the intent of tax legislation. These measures, which include both General Anti-Avoidance Rules (GAAR) and Targeted Anti-Avoidance Rules (TAAR), empower tax authorities to disregard or re-characterise transactions that lack genuine commercial substance and are carried out primarily to avoid tax. The objective is to maintain the integrity and fairness of the tax system by preventing abusive practices that exploit legislative gaps or ambiguities.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

In this episode, Nick Wright, Head of Corporate Tax and Host of ‘The Tax Hour’ is joined by Michael Sherry, Tax Counsel at Temple Tax Chambers. In this episode Michael and Nick discuss Anti-Avoidance rules within the tax system and consider recent HMRC Spotlights.

Anti-Avoidance refers to the framework of rules and principles designed to counteract tax arrangements that, while technically legal, are structured primarily to achieve a tax benefit in a way that undermines the intent of tax legislation. These measures, which include both General Anti-Avoidance Rules (GAAR) and Targeted Anti-Avoidance Rules (TAAR), empower tax authorities to disregard or re-characterise transactions that lack genuine commercial substance and are carried out primarily to avoid tax. The objective is to maintain the integrity and fairness of the tax system by preventing abusive practices that exploit legislative gaps or ambiguities.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

In this episode, Nick Wright, Head of Corporate Tax and Host of ‘The Tax Hour’ is joined by Douglas Roberts WS, Solicitor and Partner of TLT LLP, who has had involvement in over 60 sales to an EOT and now has over 25 years experience within the industry.

An Employee Ownership Trust (EOT) is a legal structure established by a company’s owners to hold a controlling interest in the business for the benefit of all employees. Introduced under the UK Finance Act 2014, the EOT model is designed to facilitate employee ownership, support long-term business continuity, and provide a tax-efficient succession route for business owners. In this episode, Nick and Douglas dive into Employee Ownership Trusts (EOTs), discussing the practical considerations of selling a business to an EOT. They also cover the latest tax requirements and compliance obligations, as well as offering real-world insights from their own experience in practice.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

Nick Wright, Head of Corporate Tax and Host of ‘The Tax Hour’ is joined by Emma Rawson, a prominent figure in the UK tax and finance sector, currently serving as the Director of Public Policy at the Association of Taxation Technicians (ATT). Emma shares her expertise in MTD with Host, Nick Wright.

Making Tax Digital (MTD) is transforming the way businesses and individuals manage their taxes. It’s a government-led initiative designed to modernise the UK tax system by moving away from paperwork and encouraging the use of digital tools for record-keeping and submissions. Initially focused on VAT-registered businesses, MTD is now expanding to include income tax and, eventually, corporation tax.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

This episode is Part 2 of a two-part special, offering an in-depth look into the 'Osmond and Allen' case and exploring the complexities of Transactions in Securities.

Nick Wright, Host of The Tax Hour Podcast & Head of Corporate Tax at Jerroms Miller Specialist Tax, welcomes Ray McCann, Consultant, past president of CIOT & and previous assistant director of HMRC, along with Pete Miller, Technical Director at Jerroms Miller Specialist Tax. With a combined 90 years of experience, they provide unparalleled insights into the Transactions in Securities legislation.

In this episode, we examine the First-tier Tribunal's significant decision in Osmond & Allen v HMRC [2024] UKFTT 378 (TC), a case that highlights the rigorous application of the Transactions in Securities (TiS) anti-avoidance rules. The discussion focuses on the taxpayers’ investment in Xercise Ltd through the Enterprise Investment Scheme (EIS) and the subsequent share buybacks that prompted HMRC’s intervention.

We analyse the Tribunal’s interpretation of the “main purpose” test, its conclusion that the transactions were primarily motivated by a desire to obtain a tax advantage, and the resulting validation of HMRC’s counteraction notices. The episode also addresses the contested limitation period for HMRC assessments and the Tribunal’s view on the six-year window under section 698(5) of the Income Tax Act 2007. Finally, we consider the broader implications for tax planning and the practical lessons this case offers to investors, advisers, and tax professionals.

We hope you can join us for this informative session.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

A special two-part episode, offering an in-depth look into the 'Osmond and Allen' case and exploring the complexities of Transactions in Securities.

Nick Wright, Host of The Tax Hour Podcast & Director at Jerroms Miller Specialist Tax, welcomes Ray McCann, Consultant, past president of CIOT & and previous assistant director of HMRC, along with Pete Miller, Head of Corporate Tax at Jerroms Miller Specialist Tax. With a combined 90 years of experience, they provide unparalleled insights into the Transactions in Securities legislation.

In the first episode, they explore the evolution of Transactions in Securities legislation, examining modern interpretations and some of the most seminal tax cases of recent decades. They also examine the role of tribunals in ensuring transparency and compliance.

If you have any questions or need further information, please get in touch. We offer a wide range of specialist tax advice for all business tax scenarios.

In this insightful episode, Jerroms Miller Specialist Tax Director and our host, Nick Wright is joined by Michael Sherry, a leading expert from Temple Tax Chambers. They dive deep into the complex world of employment-related securities. Unpacking key tax implications, recent developments, and practical advice for both employers and employees navigating these unique financial instruments.

Michael provides invaluable guidance on structuring and managing employment-related securities, from tax planning to compliance, and offers a clear understanding of how these securities impact both personal and corporate financial strategies.

Tune in to gain expert insights into this often-overlooked area of employment law and tax.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

Jerroms Miller Specialist Tax Director and our host, Nick Wright is joined by Jerroms Financial Planning Independent Financial Adviser Jamie Ellis and client William Dunne.

Together they explore tax from a client's perspective, ensuring a seamless business transition for the ultimate exit, essential shareholder strategies for protecting your business, understanding management buyouts, financial strategies for protecting your business and smart inheritance tax strategies.

If you have any questions or need further information, please get in touch. At Jerroms Miller Specialist Tax we offer a wide range of specialist tax advice for all business tax scenarios.

With significant announcements expected from the Autumn Budget taking place on 30 October at ~12:30 PM, as the UK gears up for yet another budget announcement, all eyes are on the new Labour government to see how it will navigate the current economic landscape. With the cost of living crisis still biting, inflation pressures mounting, and an economy still recovering from the pandemic, the stakes are high.

Our host Nick Wright, Director, will discuss the topics that could arise, the likeliness of changes being implemented, and how you can navigate the announcements.

Our host, Nick Wright is joined by Sean Randall, one of the UK's leading experts on Stamp Taxes.

Together they explore SDLT in depth, offering their insights on recent appeals and HMRC's approach to SDLT disputes. They'll also speculate on what SDLT changes might be announced in the Autumn Budget.