Profit on Value meaning

In this issue: Spring Statement 2025 Probate UK taxes for Private Client HMRC Manuals updates Tax avoidance, evasion and non-compliance Regulatory compliance for Private Client Contentious trusts and estates Art and heritage property, landed estates and farming families International Question of the week Daily and weekly news alerts LexTalk® Private Client: a Lexis+® community New and updated content Dates for your diary Trackers Latest Q&As Useful information Spring Statement 2025 Spring Statement 2025—key points On Wednesday 26 March 2025, the Chancellor of the Exchequer, Rachel Reeves, presented the government’s Spring Budget. There were no fresh measures for Private Client tax advisers—disappointing for those with clients likely to be affected by the planned reforms to business property relief and agricultural property relief from April 2026. Nor was there any sign of a rethink on the proposal to levy an IHT charge on pensions on death. By contrast,...

Chevin Asset Management Ltd has accused Darby & Darby in a newly public claim at the High Court of breach of an undertaking and breach of trust linked to the sale of a house in London. Chevin acquires residential homes under market value and subsequently sells them on to make a profit. The row concerns a London property owned by Paul Davies. The claim further alleges that Darby & Darby was instructed by someone masquerading as Davies. It contends that the individual who gave Darby directions was not, in truth, the real Paul Davies...

El-Khouri v Government of the United States of America [2025] UKSC 3 Background This appeal stems from a request by the US to extradite El‑Khouri, a dual British/Lebanese citizen residing in the UK. The request essentially alleges insider dealing: that El‑Khouri paid significant sums to an intermediary to obtain confidential inside information about proposed mergers and acquisitions involving companies quoted on US stock markets, and then traded in contracts for difference to profit from that information. The intermediary, who was likewise based outside the US, is said to have obtained the information from two analysts working in the London office of an investment bank. El‑Khouri is alleged to have remunerated the intermediary in cash and benefits, including funding for a yacht in Greece, a chalet in France and, on two occasions, a hotel room in New York. It is further alleged that he entered the contracts for difference through a UK broker. While their value tracked movements in the share prices of US companies, those contracts did not...

A UK-based purchaser of an overseas business should evaluate the following tax considerations: the prospective overseas and UK tax outlays linked to the acquisition tax-efficient ways to repatriate profits from the overseas entity to the UK buyer a tax-efficient exit strategy maximising the tax-efficiency of the target business This Practice Note is written from a UK tax perspective and also flags typical overseas tax points to address, including reporting, filing and compliance obligations. Local advice should be obtained in each jurisdiction in which the target operates. Overseas and UK tax costs associated with the acquisition of an overseas business The common UK and overseas tax costs relevant to acquiring an overseas business are summarised below. Transfer taxes Share acquisitions may attract local transfer or registration taxes, usually calculated as a percentage of the consideration for those shares, together with notary fees...

In October 2021, countries participating in the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) (the OECD Inclusive Framework) endorsed a ‘two-pillar’ package addressing the tax issues stemming from the digitalisation of the global economy. The two pillars constitute an ambitious effort to reform and modernise international tax rules that allocate where, and how, profits are taxed. Pillar One is chiefly (though not exclusively) aimed at the digital economy: ‘a world where enterprises can effectively be heavily involved in the economic life of different jurisdictions without any significant physical presence and where new and often intangible value drivers increasingly come to the fore’. Pillar One introduces two elements: a new taxing right that stretches beyond traditional tax nexus rules anchored in physical location (Amount A) a standardised methodology for transfer pricing baseline marketing and distribution activities between related parties (Amount B). This Practice Note provides a high-level summary of: the tax...

This Practice Note explores the principal legal terms typical of social housing finance and what distinguishes them from financing in other sectors. It focuses on standard financial covenants and other sector‑specific provisions, including events of default, together with terms linked to the availability of long‑term fixed rate interest options. For more on social housing finance transactions, see Practice Notes: Social housing entities entering into finance transactions Key deal structures in social housing finance Taking and enforcing security from social housing entities This Practice Note concentrates solely on private not‑for‑profit providers of social housing registered in England (referred to as ‘RPs’), as they comprise the vast majority of private debt finance raised by housing associations to date. It does not cover providers registered in Wales. Financial covenants—introduction The principal financial covenants in social housing finance are: loan to value gearing interest cover (less commonly) net rental income cover from charged properties Loan...

A: General information Date of annual review Person(s) carrying out the annual review B: Review and findings Are your financial management policies and procedures current and suitable for their purpose? ☐ Yes ☐ No—if No, record an action in section C below to revise your policies and procedures. Do your actual monthly and annual results align with your forecasts, particularly regarding: profit and loss? cash flow? balance sheet? (Only accept a reasonable margin of variance) ☐ Yes ☐ No If No, is a re-forecast of your financial performance required? ☐ Yes—ensure an action is set at section C below to deal with this ☐ No Are you confident that your monitoring arrangements function as intended for the following: the value of work undertaken on clients’ files (i.e. work in progress) relative to any payments on account of costs? the level of credit you extend to clients? aged debtors? time recording?...

3 Collaboration Objectives and Steering Group The parties agree to: Maximise the overall value of the Development Site, taking account of good planning practice. Settle the Master Plan as soon as reasonably practicable. Secure a Satisfactory Planning Permission for the Development (including Enabling Works and Shared Infrastructure), and thereafter: obtain any agreed Funding; deliver the Enabling Works and Shared Infrastructure promptly, efficiently and on time; and approve and implement the Sale Strategy. Apportion the Collaboration Expenses and any Development Profit or Development Loss in the stated Proportions, unless this Agreement provides otherwise. The Steering Group must: Provide strategic direction to achieve the Collaboration Objectives, including agreeing variations, monitoring progress and issuing instructions. Meet at least monthly (or more often if required); each party will use all reasonable endeavours to ensure its representative, or a suitably senior substitute, attends; minutes are to be taken on rotation and circulated within five Working Days. Invite appointed consultants and...