Please enable JavaScript.
Coggle requires JavaScript to display documents.
BPT open book course notes - Coggle Diagram
BPT open book course notes
Basics
1a. Choice of biz structure (Inc or not?)
1b. Unincorporated business: basic rules
Trade profits
Capital allowances
Basis periods
Partnerships
Uninc trader loss relief
1c. Companies
Company loss relief:
trading, non trading, restriction on losses bf, losses on change of ownership
CT proforma
R&D expenditure SME / large
IFAs (inc. patent box)
Goodwill
Size and rues
Companies with investment businesses
1d IT proforma, rates and NICs table
Incorporation
Incorp. Christina summary
Options for gains on incorporation Chris. summary
Retaining personal ownership of land and buildings
Planning issues
When to elect to
dis-apply
for incorp relief (BADR?)
Gift relief or Incorp relief?
Anti-avoidance
Withdrawal of profits: implications for the person & company
Owner manged businesses
Use of PSCs
OPW
IR35
Employment vs self employment tests
Close companies
: loans, taxable benefits and qualifying interest payments
Disc. of tax avoidance schemes
DOTAS
DASVOIT
Promoters of tax advantage schemes
POTAS
GAAR
(HMRC's catch all)
Accelerated payment notice (
APN
) [DOTAS/GAAR]
Managed service companies (MSCs)
Corporate anti avoidance
Value shifting
CFCs
Transfer pricing
Thin capitalisation
CIR
DPT (25%)
Hybrid mismatch
Large cos requirement to publish tax strat.
Data analytics (PAYE RTI)
Company repurchase of shares
Close co vs connected co reminders
Raising finance
Debt
Equity
VC Trusts
EIS & SEIS (notes for each)
5
VAT and Stamp
VAT groups
Deregistration
CGS
Supply of L&B
Regular
OTT
L&B in a TOGC
VAT overseas services
Stamp duty (shs & securities)
SDLT rates and notes
SDLT on rentals
ATED
6
CGT & reliefs
Christ. overview
Exempt assets
Deferred consideration
CGT reliefs
ROR
Gift relief
BADR / Investors' relief
Incorporation relief
Takeovers
from holders of orig. shares POV:
Cash (immediate gain)
Shares (paper for paper)
Debentures (QCB)
IHT & reliefs
Christ. summary
BPR & APR
IHT reliefs
BPR / APR
36% charitable giving rate
QSR
Normal expenditure out of income
Taper relief
Fall in value relief
Deed of variance
Share values
Spouse rules
RNRB (£175k) and reduction over £2mil
IHT anti avoidance:
GWROB
POAT
Trusts
Employees, pensions and redundancies
BIKs
Employee share option schemes
Non tax advantaged
Tax advantaged
CSOP
EMI
SAYE
Employee share schemes:
Share incentive plan (SIP) where company gives away shares or incentivises purchase
no option attached
Termination payments: [exempt / taxable / part-ex]
Pensions
Occupational (inc Small self administered scheme)
Personal (inc Self invested personal scheme)
Leases & property businesses
Property leases
Gains on leases
Investing in residential property
Investing in commercial property
Sale and leaseback
Groups & reliefs
Loss groups
Consortium relief
ConCo losses
Con Member losses
Gains groups (chargeable gains)
group ROR
pre entry gains/losses
de-grouping charges
Approach to group questions and strats:
Group rels
Calc TTP for each (pre any loss rels)
Group losses b/f
Gains group transfers
Trading losses in chronological order
Group admin and payment
11.
Individuals: overseas aspects
Domicile position, including deemed-dom
Residency position, including split year basis
IHT aspects
Deemed domilce
Election for UK domicile
DTR
Location of assets for IHT
Valuation of foreign assets (-5%)
CGT aspects
Basis of assessment
DTR
Remittance basis
Non UK residents and UK property
Deemed doms & CGT
Penalties for off shore evasion
IT aspects
Remittance basis
Employment income
Other income
Tax treaties: impact
DTR
Temporary non residence: IT/CGT
Companies: overseas aspects
Company residence
Company migration
Establishing an overseas business
Overseas sub
Overseas PE
Overseas aspects of group relief
Incorporating an o/s PE
DTR
Treaty relief
Unilateral (credit) relief
Interaction with loss/group relief
Expense relief
Escaping the charge to UK CT
UK resident incorporates o/s PE
Migration of UK resident co.
Overseas anti avoidance
Trans pricing; Thin cap; CFCs; CIR; DPT; Hybrid mismatch
CFC stock answer
Disposal of business
Sale of ST biz Christ. summary
Disposal of incorporated biz
Sale of shares
Sale of trade and assets
Re-organisation (trans of trade in a 75% group)
Hive downs
MBOs and relief for financing
De-mergers
(co passes its shareholding in a sub to its own SHs)
De-merger relief
Value shifting
Depreciatory transactions
Bankruptcy of ST/partners:
Voluntary or involuntary
Liquidation of a company
Christ. summary
Striking off Co. House
Disincorporation
Liquidation: complete overview
Admin, HMRC, Ethics
Filing deadlines
Election deadlines
Avoidance & evaision
Ethics
scenarios
Steps when accepting a new client
Examiner recommends approach
Planning ideas:
IT / CGT / IHT / CT & gains