(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of in

Question

(iii) State the value added tax (VAT) and stamp duty (SD) issues arising as a result of inserting Bold plc as

a holding company and identify any planning actions that can be taken to defer or minimise these tax

costs. (4 marks)

You should assume that the corporation tax rates for the financial year 2005 and the income tax rates

and allowances for the tax year 2005/06 apply throughout this question.

Answer 1

正确答案：
(iii) Bold plc will be making a taxable supply of services, likely to exceed the VAT threshold. It should therefore consider
registering for VAT – either immediately on a voluntary basis, or when its cumulative taxable supplies in the previous
twelve months exceed ￡60,000.
As an alternative, the new group can apply for a group VAT registration. This will simplify its VAT administration as intragroup
transactions are broadly disregarded for VAT purposes, and only one VAT return is required for the group as a
whole.
Stamp duty normally applies at 0·5% on the consideration payable in respect of transactions in shares. However, an
exemption is available in the case of a takeover, reconstruction or amalgamation where there is no real change in
ownership, i.e. the new shareholdings mirror the old shareholdings, and the transaction is for commercial purposes. The
insertion of a new holding company over an existing company, as proposed here, would qualify for this exemption.
There is no VAT on transactions in shares.