Might be a [***] up, but from the conduct of the taxpayer i'm not surprised things like accelerated payments have been introduced.
There will be a financial adviser involved and therefore documentation. If not known phone the customer services department who may be able to point you in right direction.
There are too many products to able to tell which it is and therefore what tax treatment is.
You should have something akin to a chargeable event certificate.
Just in case you were being serious you can't just deduct pay from an employee because you feel like it. There are only certain categories of deductions you can.
CTA 2009 s46(1) follow the accounts subject to any adjustment required or authorised by law in calculating profits.
When you sell the assets you are subject to Corporation tax on the chargeable profits at that time which is an adjustment required. I'll leave it as an exercise for you to find that legislation....
I was using an out of date tolleys book (tut tut me!)
Try TCGA s136 / Sch5AA and SI 2009/3001 Regulation 36
You essentially get roll over of gains going from Non Reporting to Non-Reporting.
The fund manager running the re-construction would normally be providing high level tax advice in relation to the merger. It might be worth looking at the documentation. This may not be applicable if the fund was not marketed to UK or insufficient AUM in the UK to make it cost effective,
Well its a dividend from a South African company so Foreign (from memory there is WHT there to too claim)
100% CA still available for energye efficent products on certain lists?
Ignore the SPV for the moment. If your client was buying a house doing it up then selling it on 6 months later would that be a capital transaction or revenue? Repeat this 10 times, does your analysis change?