
Investment Companies
Tax-Optimised Structures for Portfolio Growth
- Corporation tax advantages - 19-25% rates (FY24) vs 45% income tax + 39.35% dividend tax
- Dividend streaming - Cross-class share structures for profit extraction at 8.75%/33.75% rates
- Substantial shareholding exemption - Qualifying for 0% CGT on trading company disposals (SSE rules)
- Loan relationships regime - Deductible financing costs under corporate interest restriction (CIR)
- Reporting requirements - NRCGT filings and CTSA compliance for corporate chargeable gains
- Fund structuring - Tax-transparent vs opaque vehicles (REIT, VCT comparison)
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