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Substantial Shareholdings Exemption
{{UKtaxation The substantial shareholdings exemption is an exemption from assessment of capital gains under corporation tax applicable to United Kingdom companies. The exemption is found in Schedule 7AC of the Taxation of Chargeable Gains Act 1992. The rationale for the exemption is that groups of companies should be able to restructure without having to concern themselves with taxation of capital gains. Other European jurisdictions apply a more comprehensive system. For example, in Luxembourg and the Netherlands as well as in Germany and Belgium, both capital gains derived from, as well as dividend income earned on, qualifying shares are (mostly) exempt from further local taxation. These comprehensive systems are generally referred to as participation exemption systems. Eligibility To qualify for the exemption, a disposal must meet all of the following criteria: * The disposing company must dispose of shares or an interest in shares of another company. * The company must h ...
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Tax Exemption
Tax exemption is the reduction or removal of a liability to make a compulsory payment that would otherwise be imposed by a ruling power upon persons, property, income, or transactions. Tax-exempt status may provide complete relief from taxes, reduced rates, or tax on only a portion of items. Examples include exemption of charitable organizations from property taxes and income taxes, veterans, and certain cross-border or multi-jurisdictional scenarios. A tax exemption is distinct and different from a tax exclusion and a tax deduction, all of which are different types of tax expenditures. A tax exemption is an income stream on which no tax is levied, such as interest income from state and local bonds, which is often exempt from federal income tax. Additionally, certain qualifying non-profit organizations are exempt from federal income tax. A tax exclusion refers to a dollar amount (or proportion of taxable income) that can be legally excluded from the taxable base income prior to a ...
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Capital Gains
Capital gain is an economic concept defined as the profit earned on the sale of an asset which has increased in value over the holding period. An asset may include tangible property, a car, a business, or intangible property such as shares. A capital gain is only possible when the selling price of the asset is greater than the original purchase price. In the event that the purchase price exceeds the sale price, a capital loss occurs. Capital gains are often subject to taxation, of which rates and exemptions may differ between countries. The history of capital gain originates at the birth of the modern economic system and its evolution has been described as complex and multidimensional by a variety of economic thinkers. The concept of capital gain may be considered comparable with other key economic concepts such as profit and rate of return; however, its distinguishing feature is that individuals, not just businesses, can accrue capital gains through everyday acquisition and di ...
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United Kingdom Corporation Tax
: ''Throughout this article, the term "pound" and the £ symbol refer to the Pound sterling.'' Corporation tax in the United Kingdom is a corporate tax levied in on the Profit (economics), profits made by UK-resident Company (law), companies and on the profits of entities registered overseas with permanent establishments in the UK. Until 1 April 1965, companies were taxed at the same Taxation in the United Kingdom#Income tax, income tax rates as individual taxpayers, with an additional profits tax levied on companies. Finance Act 1965 replaced this structure for companies and associations with a single corporate tax, which took its basic structure and rules from the income tax system. Since 1997, the UK's Tax Law Rewrite ProjectTax Law Rewrite
, Her Majesty's Revenue and Customs (HMRC). Retrieved 17 April 2007
has been modernising the ...
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United Kingdom
The United Kingdom of Great Britain and Northern Ireland, commonly known as the United Kingdom (UK) or Britain, is a country in Northwestern Europe, off the coast of European mainland, the continental mainland. It comprises England, Scotland, Wales and Northern Ireland. The UK includes the island of Great Britain, the north-eastern part of the island of Ireland, and most of List of islands of the United Kingdom, the smaller islands within the British Isles, covering . Northern Ireland shares Republic of Ireland–United Kingdom border, a land border with the Republic of Ireland; otherwise, the UK is surrounded by the Atlantic Ocean, the North Sea, the English Channel, the Celtic Sea and the Irish Sea. It maintains sovereignty over the British Overseas Territories, which are located across various oceans and seas globally. The UK had an estimated population of over 68.2 million people in 2023. The capital and largest city of both England and the UK is London. The cities o ...
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Companies
A company, abbreviated as co., is a legal entity representing an association of legal people, whether natural, juridical or a mixture of both, with a specific objective. Company members share a common purpose and unite to achieve specific, declared goals. Over time, companies have evolved to have the following features: "separate legal personality, limited liability, transferable shares, investor ownership, and a managerial hierarchy". The company, as an entity, was created by the state which granted the privilege of incorporation. Companies take various forms, such as: * voluntary associations, which may include nonprofit organizations * business entities, whose aim is to generate sales, revenue, and profit * financial entities and banks * programs or educational institutions A company can be created as a legal person so that the company itself has limited liability as members perform or fail to discharge their duties according to the publicly declared incorporat ...
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Taxation Of Chargeable Gains Act 1992
The Taxation of Chargeable Gains Act 1992 (c. 12) is an act of Parliament which governs the levying of capital gains tax in the United Kingdom. This is a tax on the increase in the value of an asset between the date of purchase and the date of sale of that asset. The tax operates under two different regimes for a natural person and a body corporate. For a natural person, the rates of the capital gains tax are the same as those for earned income. The tax is levied at a rate determined by the highest rate of income tax which that person pays. Each year a natural person has an amount of gain, fixed by law, which is exempt from tax. By contrast, for bodies corporate, the chargeable gain is treated as additional profits for the accounting period in question. The capital gains tax is charged as additional corporation tax. Bodies corporate have no allowance for gains free from tax. Various reliefs from capital gains tax exist. These include indexation relief, where the amount of gain ...
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Restructuring
Restructuring or Reframing is the corporate management term for the act of reorganizing the legal, ownership, operational, or other structures of a company for the purpose of making it more profitable, or better organized for its present needs. Other reasons for restructuring include a change of ownership or ownership structure, demerger, or a response to a crisis or major change in the business such as bankruptcy, repositioning, or buyout. Restructuring may also be described as corporate restructuring, debt restructuring and financial restructuring. Executives involved in restructuring often hire financial and legal advisors to assist in the transaction's details and negotiations. It may also be done by a newly-hired CEO specifically to make the difficult and controversial decisions, required to save or reposition the company. It generally involves financing debt, selling portions of the company to investors, and reorganizing or reducing operations. The basic nature of restr ...
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Taxation
A tax is a mandatory financial charge or levy imposed on an individual or legal person, legal entity by a governmental organization to support government spending and public expenditures collectively or to Pigouvian tax, regulate and reduce negative Externality, externalities. Tax compliance refers to policy actions and individual behavior aimed at ensuring that taxpayers are paying the right amount of tax at the right time and securing the correct tax allowances and tax relief. The first known taxation occurred in Ancient Egypt around 3000–2800 BC. Taxes consist of direct tax, direct or indirect taxes and may be paid in money or as labor equivalent. All countries have a tax system in place to pay for public, common societal, or agreed national needs and for the functions of government. Some countries levy a flat tax, flat percentage rate of taxation on personal annual income, but most progressive tax, scale taxes are progressive based on brackets of yearly income amounts. Most ...
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Participation Exemption
Participation exemption is a general term relating to an exemption from taxation for a shareholder in a company on dividends received, and potential capital gains arising on the sale of shares. Background The justification for a participation exemption is to eliminate double taxation of shareholders. In any accounting period, a company may pay a form of corporate income tax on its taxable profit which reduces the amount of post-tax profit available for distribution by dividend to shareholders. In the absence of a participation exemption, or other form of tax relief, shareholders may pay tax on the amount of dividend income received. This results in double taxation as the dividend is paid out of taxed profits of the company. A participation exemption will typically provide that certain types of dividends are not taxed in the hands of shareholders. In addition, many participation exemption regimes provide that capital gains on shares are not taxed as long as a specified ...
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Stock
Stocks (also capital stock, or sometimes interchangeably, shares) consist of all the Share (finance), shares by which ownership of a corporation or company is divided. A single share of the stock means fractional ownership of the corporation in proportion to the total number of shares. This typically entitles the shareholder (stockholder) to that fraction of the company's earnings, proceeds from liquidation of assets (after discharge of all Seniority (financial), senior claims such as secured and unsecured debt), or Voting interest, voting power, often dividing these up in proportion to the number of like shares each stockholder owns. Not all stock is necessarily equal, as certain classes of stock may be issued, for example, without voting rights, with enhanced voting rights, or with a certain priority to receive profits or liquidation proceeds before or after other classes of Shareholder, shareholders. Stock can be bought and sold over-the-counter (finance), privately or on ...
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Common Stock
Common stock is a form of corporate equity ownership, a type of security. The terms voting share and ordinary share are also used frequently outside of the United States. They are known as equity shares or ordinary shares in the UK and other Commonwealth realms. This type of share gives the stockholder the right to share in the profits of the company, and to vote on matters of corporate policy and the composition of the members of the board of directors. The owners of common stock do not directly own any assets of the company; instead each stockholder owns a fractional interest in the company, which in turn owns the assets. As owners of a company, common stockholders are eligible to receive dividends from its recent or past earnings, proceeds from a sale of the company, and distributions of residual (left-over) money if it is liquidated. In general, common stockholders have lowest priority to receive payouts from the company. They may not receive dividends until the company ...
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Profit (accounting)
Profit, in accounting, is an income distributed to the ownership , owner in a Profit (economics) , profitable market production process (business). Profit is a measure of profitability which is the owner's major interest in the income-formation process of market production. There are several profit measures in common use. Income formation in market production is always a balance between income generation and income distribution. The income generated is always distributed to the Stakeholder (corporate), stakeholders of production as economic value within the review period. The profit is the share of income formation the owner is able to keep to themselves in the income distribution process. Profit is one of the major sources of economics , economic well-being because it means incomes and opportunities to develop production. The words "income", "profit" and "earnings" are synonyms in this context. Other terms See also * Gross income * Net profit * Profitability index * Rate ...
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