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Rayney’s Tax Planning for Family and Owner-Managed Companies: 2023/24

Author:
Peter Rayney FCA, CTA (Fellow), TEP
Publisher:
Bloomsbury Professional
Publication Date:
2024
Law Stated At:
6 April 2024
E Earn-outs background, 15.64 base cost apportionment, 15.74 bonus arrangements, as, 15.67 deemed non-QCB treatment, 15.73 election to carry back capital loss, 15.66 income tax, and, 15.79 – 15.81 loan notes, in, 15.72 – 15.72 Marren v Ingles decision, 15.65 NICs, and, 15.79 – 15.81 opting out of deemed s 138A TCGA 1992 deferral treatment, 15.77 ‘profit warranty’ approach, 15.70 QCBs, and, 15.75 security, 15.76 shares, in, 15.72 – 15.72 valuation of right generally, 15.69 ‘profit warranty’ approach, 15.70 worked example (cash-based earn-out), 15.68 worked examples (loan notes), 15.78 Earnings taxation, 5.6 valuations, and majority shareholdings, 14.50 – 14.52 minority shareholdings, 14.53 – 14.54 Earnings multiples valuations, and, 14.30 EBITDA multiples valuations, and, 14.19 EBTs deemed ‘earning s’ charge on loans outstanding on 5 April 2019 background, 5.20A dealing with charge, 5.20B – 5.20C HMRC ability to transfer tax to employee, 5.20C insolvent companies, and, 5.20D reporting and paying the ...

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