Encountering intangibles

25 May 2018

HMRC’s intangibles consultation may well produce improvements to the legislative code.

In the meantime, difficulties can arise on pre-sale reorganisations and break-up transactions, although some of these can be solved through structuring. Particular care is needed when dealing with partnerships, as that aspect of the regime is no longer coherent.

In this article, first published in Tax Journal, Gregory Price sets out some practical suggestions for dealing with these issues.