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Question 1

A non-UK resident is chargeable to UK CGT in respect of the disposal of shares in a company whose interests in UK land make up at least …. of its gross assets

The gain is chargeable if the non-resident owns at least …. of the company

In what circumstance is the disposal not chargeable (or loss allowable)?

Answer 1

75%

25%

If at the time of disposal at least 90% of the land owned by the company is used for a qualifying trading purpose.

Question 2

Indirect disposals of interest in UK land by non residents.

If the shares were acquired on or after 6 April 2019…..

If the shares were acquired before 6 April 2019…

Answer 2

The normal share disposal rules apply

Only the gain since 6 April 2019 is chargeable.

*The default method of calculation requires the shares to be valued at 5 April 2019.

**The individual can elect to use retrospective method ie using original cost however in this case any capital loss arising is NOT ALLOWABLE.

Question 3

All NRCG gains and losses must be reported using the UK property disposal service within ……..

Tax must be paid….

Answer 3

60 days of the date of completion of the disposal

*even if there is no tax to pay

at the same time

Question 4

When adjusted net income over £100k we restrict the PA available.

PA 12,570
Less : 1/2 (Adjusted net income - 100,000)
Revised PA

What is included in the adjusted net income?

Answer 4

NS+S+D - gross personal pension payments - gross gift aid

Question 5

Purchase of own shares / buy backs

What is the income treatment for the income distribution?

Answer 5

Amount received on buy back X

Less: OG subscription price
(usually nominal value (X)

Dividend received X

Question 6

Purchase of own shares / buy backs

What is the income treatment for the capital gain?

Answer 6

OG subscription price X
(usually nominal value)

Less: Actual cost (X)

Capital gain/loss X

Question 7

Purchase of own shares / buy back.

Under the capital treatment there is no income distribution. A capital gain is calculated by………..

Answer 7

Sale proceeds
(ie amount received on buy back X

Less: Actual cost (X)

Capital gain / loss X

Question 8

The CAPITAL TREATMENT APPLIES WHERE ..

Answer 8

1. Repurchase by unquoted trading co which is not 51% sub of quoted co

AND EITHER
- Repurchase wholly/mainly for benefit of trade ; and
- Buy back from UK res vendor who held shares for at least 5 years ; and
- Vendor reduces interest by at least 25%; and
- Following buy back, vendor is not connected with company (holds under 30% shares)

OR
- Money from repurchase used wholly/mainly to discharge IHT and without it, would have caused hardship

Question 9

Regarding the tapering of the annual allowance, what is the minimum that it can go down to?

Answer 9

£10,000

Question 10

Regarding annual allowance calculation, threshold income refers to?

Answer 10

Net income - gross personal pension contributions made by individual

Question 11

Regarding annual allowance calculation, adjusted income refers to?

Answer 11

Net income + employer contributions to scheme