Management expenses
Apportionment of (UK and foreign income)
Commentary –
Woolley on Financial Planning with Trusts 16.4.2
Authorised unit trust amalgamating/converting to open-ended investment company
Legislation/Regulatory –
SI 2006/964 reg. 80
Calculation of taxable rental income
Commentary –
Golding and Connolly on Advising British Expats 5.14
;
Golding and Connolly on Living and Working Abroad 6.10.14
Companies with investment business
Company with investment business, restriction on deduction
Corporate landlords
Commentary –
Chanda on Property Investment 6.8.5
Delisting of shares
Case Law –
Dawsongroup Ltd [2009] TC 00105
Group relief
Commentary –
Quick Overview ¶36265
;
Ford on Tax Losses 9.2.1
HMRC guidance
Commentary –
Woolley on Financial Planning with Trusts 7.3.4
Insurance companies
– see Insurance companies
Investment companies
Generally
Commentary –
Quick Overview ¶23010–Quick Overview ¶23020
Life assurance business, deduction
Case Law –
Johnson (HM Inspector of Taxes) v. Prudential Assurance Co Ltd. [1998] BTC 112
;
Johnson (HM Inspector of Taxes) v Prudential Assurance Co Ltd. [1996] BTC 375
Manufactured dividends, paid out of Caymans Islands company share premium account
Case Law –
First Nationwide [2010] TC 00339
;
First Nationwide v Revenue and Customs Commissioners. [2011] BTC 1,640
;
Revenue and Customs Commissioners v First Nationwide. [2012] BTC 99
Mineral royalties
Legislation/Regulatory –
ITTOIA2005 s. 339
Oil extraction activities
Legislation/Regulatory –
CTA2010 s. 303
Restrictions re company losses
Commentary –
Ford on Tax Losses 8.2.10
Trust income
Commentary –
Quick Overview ¶62285
Trustees
Commentary –
Quick Overview ¶62205
Trusts with vulnerable beneficiaries
Commentary –
Tax Reporter ¶355-450
HMRC Guidance –
TSEM3440
Waste disposal landfill site restoration payments
Case Law –
Dispit Ltd v. R & C Commrs (2007) Sp C 579