Satwaki Chanda
Satwaki Chanda is a tax lawyer with over 15 years tax experience, having worked for City law firms and a Big Four accountancy practice.
He has experience in a variety of matters, including corporate transactional work, advising entrepreneurs and SMEs, investment funds and real estate planning.
He is currently occupied with his website Tax Notes (taxnotes.co.uk), an educational site containing articles on UK taxation, with a particular emphasis on business and property taxes.
He has experience in a variety of matters, including corporate transactional work, advising entrepreneurs and SMEs, investment funds and real estate planning.
He is currently occupied with his website Tax Notes (taxnotes.co.uk), an educational site containing articles on UK taxation, with a particular emphasis on business and property taxes.
Practice Area
Panel
- Contributing Author
4 Contributions by Satwaki Chanda
PRACTICE NOTES
UK capital gains tax: Business Asset Disposal Relief—eligibility, 2025–26 rate changes, personal company/trading tests, EMI, partnerships, trusts, associated disposals, share exchanges, claims and lifetime limit
FORTHCOMING CHANGE relating to call for evidence on tax support for entrepreneurs:
At Budget 2025, the government issued a call for evidence (deadline: 28 February 2026) examining how existing tax incentive programmes function and exploring ways to bolster support for entrepreneurs. It reviews the impact of current reliefs and potential avenues for additional assistance to entrepreneurs within the tax system. The exercise concentrates in part on the venture capital schemes and on enterprise management incentives. It also considers investors’ relief and, in particular, invites views on how the tax framework can facilitate reinvestment by successful entrepreneurs, including the purpose and effectiveness of business asset disposal relief. Business asset disposal relief (BADR), previously known as entrepreneurs’ relief for tax years before 2020–21, is a capital gains tax (CGT) relief intended to encourage people to found and grow their own businesses. Where the qualifying conditions are met, the relief operates to reduce the CGT rate payable on disposals of certain business assets. BADR is charged at the same rate as investors’ relief (the BADR Rate), with the BADR Rate set at 10% up to 5 April 2025 during that period...
Tax
PRACTICE NOTES
UK CGT investors’ relief: eligibility, rates, lifetime limit, interaction with BADR, trading/employment conditions, trustees, reorganisations and QCBs, connected-person traps, claims, anti-forestalling and transitional rules (2025–26 changes)
FORTHCOMING CHANGE relating to call for evidence on tax support for entrepreneurs:
At Budget 2025, the government launched a formal public call for evidence (closing date: 28 February 2026) on how existing tax incentive arrangements operate and on potential measures to extend support for entrepreneurs. The exercise concentrates in part on the venture capital schemes and on enterprise management incentives. It also references investors’ relief and, more specifically, invites views on how the tax regime might better enable reinvestment by successful entrepreneurs, including the function and effectiveness of business asset disposal relief. Investors’ relief is a capital gains tax (CGT) relief intended for individuals who invest in unquoted trading companies while not taking part in the management or operation of the business. Such investors will not generally qualify for business asset disposal relief (BADR, formerly entrepreneurs’ relief, see Practice Note: CGT—business asset disposal relief (formerly entrepreneurs' relief)) when they realise their investment and, without investors’ relief, would instead be charged at the standard CGT rates. Investors’ relief applies the same rate of tax as BADR (the Investors’ Relief Rate). The Investors’ Relief Rate is 10% until 5 April 2025...
Tax
PRACTICE NOTES
UK company disposals, group reorganisations and migrations: secondary tax liabilities and recovery across CT, CGT, SDLT/LBTT/LTT, VAT, IR35, PPT, CFCs and Pillar Two
Secondary liabilities
UK tax legislation includes a range of rules under which one individual can be held accountable for another’s tax debt; these are referred to as secondary liabilities. This Practice Note concentrates primarily on secondary tax liabilities that may arise on the sale of a company, with implications for both parties to the transaction. For instance, the target could become secondarily liable due to a default elsewhere within the seller’s group. A buyer will be reluctant to shoulder that expense and will therefore seek protection by pursuing a claim under the tax covenant or warranties to safeguard its position.
The target might also incur primary liabilities that crystallise after it joins the buyer’s group but which relate back to periods when it belonged to the seller’s group. In such cases, members of the seller’s group may themselves face secondary tax liabilities. The seller will seek suitable protection where the primary liability has arisen because of a default or other event within the buyer’s control. For example:
the buyer may implement radical alterations to the target company’s business (see Change in ownership rules below)—potentially triggering a secondary liability...
Tax
CHECKLISTS
UK company takeovers: secondary and transferred tax liabilities—table of statutory provisions, liable parties, assessment time limits and indemnities
This table sets out the circumstances in which a company can sometimes be held responsible for taxes mainly owed by another party, within the context of a company takeover event. It should be read together with the more comprehensive explanation of each provision set out in Practice Note: Secondary tax liabilities of companies, for clarity.
Description
Legislation
Who is secondarily liable?
When does liability arise?...
Tax
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