May Newsletter | Tax Matters That Matter | Corporate Edition 5 by ETC Tax

Corporate Issue Edition Five

TAX MATTERS That's so meta Alexander deep dives into the world of blockchain technologies and crypto to discuss the benefits of research and development tax relief.

‘REDOMICILE’ OF OFFSHORE COMPANIES

SPLITTING A COMPANY

– Demergers and HMRC clearance applications

VAT & PROPERTY

- A brief overview

Thinking of getting started in Cryptocurrency? Ensure that the tax treatment of the way you invest in crypto is properly considered from the outset.

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Contents

May 2022 Edition

First word

" I could change the world one square of chocolate at a time " - Jo Fairley Co – Founder of Green & Black Chocolate.

Features

That's so meta – A deep dive into the world of blockchain technologies and crypto

‘Redomicile’ of Offshore Companies – Looking at legislative changes made over recent years

s we enter a new month, we have expanded our team, the prep for our summer social is well underway and Tax Dog has been busy getting ready for the jubilee celebrations! We have plenty of content this month so please take some time to read the latest edition of Tax Matters that Matter! This month we bring you… • That’s so meta – Alexander Wilson deep dives into the world of blockchain technologies and crypto to discuss the benefits of research and development tax relief. • ‘Redomicile’ of offshore companies – Clive Haworth focuses on the legislative changes made over recent years regarding offshore companies owning UK residential and commercial properties. • Splitting a company – Zeeshan Khilji talks demergers and HMRC clearance applications.

A tale of two chocolatiers – ETC Tax's first annual tax conference at Mere Golf and Spa Resort

• Zeeshan Khilji bring us the case of the month – EMI share option schemes and accelerated vesting. • VAT and Property – Keith Miller has the answers on property-related matters, both commercial and residential. • A tale of two chocolatiers – Andy Wood summarises our annual conference on Succession. This month we have put Harry Stuart our Senior Digital Marketing Executive under the spotlight. As always we have our usual round up of goings on here at ETC Tax. Many thanks to Sarah Aston and all the contributors who made this edition happen. As always, if you have any queries, comments or observations then please let us know. We’d love to hear from you. Best wishes

Regulars

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In the spotlight Bulletin

Zeeshan Khilji Associate Director zeeshan.khilji@etctax.co.uk 3

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so meta Alexander deep dives into the world of blockchain technologies and crypto to discuss the benefits of research and development tax relief.

s I wrote recently on our blog (1st November 2021 – “Crypto Tax Planning”), crypto activities are becoming ever more sophisticated. A year ago, our crypto clients were individual traders, buying and selling tokens for a profit. Now, we are advising metaverse developers, developers of GameFi projects and successful NFT artists. An area we are now focusing on with many clients is research and development. Blockchain is cutting-edge technology and so the space is ripe for this generous relief. For a small or medium company, a successful claim for R&D will result in 230% of qualifying expenditure being deducted from the bottom line for taxable profit or an immediate cash payment from HMRC of 33.35% of the expenditure for a loss-making company. A company spending £200,000 on qualifying activity would reduce taxable profit by £460,000. A loss-making company would be able to claim a cash payment of £66,700 instead.

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R&D is defined for tax purposes as a project which seeks to achieve an advance in science or technology through the resolution of scientific or technological uncertainty. Innovation The building block of crypto is the blockchain and developers are now flexing its power and potential application. R&D is defined for tax purposes as a project which seeks to achieve an advance in science or technology through the resolution of scientific or technological uncertainty. The projects on which we are advising are all built on one or other of the current blockchains, such as Ethereum, Fantom or Polygon. Each blockchain has its own underlying code, is developed independently and is pre-existing. Thankfully, for R&D you don’t have to develop an entirely new technology – working with an existing technology to solve a novel problem or modifying or integrating it in a unique manner or developing a new and unique service could qualify just as well. To qualify for R&D relief, a company must meet a ‘two-limb’ test: • I s the company achieving a technological advance in the field of science and technology? •A t the outset of the project, is there technological and scientific uncertainty, which the company would need to resolve to be able to achieve the advance? To illustrate, we can look to some of the casework we have been working on. 6

Martian Premier League Martian Premier League are developing a football manager style game which will be deployed over the Polygon network. The Polygon network is an existing technology. Football manager style games have been a staple of footballer-wannabegeeks for a decade or more. So, where is the R&D potential? An area being explored on this project is adapting the Polygon network technology so that it can support elements of the game. The developers are keen that the game will function entirely over the blockchain, rather than simply having elements of it (such as NFT’s representing players) existing on the blockchain as is the case for other blockchain games. This means that smart contracts will have to be developed to resolve and record events in the game (e.g., working out whether Team A or Team B win a match, calculating the impact of all the different characteristics of the players on each team and their impact on the gameplay). A similar problem is working out how players of the game will be able to invest earned exchange tokens to “train” their players, to improve different “skills”. Generally, the owner of an NFT is not able to change its characteristics, so this would be a clear innovation.

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Alexander Wilson Tax Manager alexander.wilson@etctax.co.uk

Taking those discrete projects and holding them up against the definition for R&D, we can see a plausible case for there being a technological development. The developers here are taking the existing technology of the Polygon network code and working out how that code will allow these innovations to work. The project requires working through uncertainty; the team have an objective in mind but how it will be done and what the solution will look like (or indeed, whether it is actually possible) are all unknowns. In this case, the team have secured significant investment and so cashflow may not be a key concern. Being able to legitimately reduce profits for the purposes of tax means that our assistance in making a claim for R&D will make the project all the more viable and increase retained profit for future investment and development. The Metaverse An example of improved efficiency which could qualify for R&D can be seen in the case of more than one client who are trying to find ways to reduce gas fees on blockchain transactions.

Returning to the metaverse project; each transaction requires a gas fee: • Renting out plots; • Distributing income to NFT holders; • Building on plots and so on. To achieve a seemingly simple transaction may require a sequence of complex smart contracts in the background. Gas fees are based on the data involved in the transaction; a complex smart contract will cost more than would a simple one. Accordingly, a project working on solutions to streamline the smart contracts for a transaction could well amount to a qualifying technological advancement. We have barely scratched the surface of the kinds of technological developments taking place in this space. Any blockchain developer should carefully consider whether the work they are doing would qualify for this extremely generous relief. It could be the difference needed for a successful launch.

Every transaction on the blockchain requires a gas fee. For example, an interaction on the Binance Smart Chain (BSC) will require a small fee paid with BNB (the Binance exchange token). This is the fee awarded to miners who record transactions on the distributed nodes which make up the network. So, writing a smart contract and ‘uploading’ it to the blockchain will cost a fee, as will Interacting with that smart contract.

Enjoying this article, but need more advice on any of the topics covered? To discuss how ETC can help with your tax questions call the team on 0161 711 1320 or email enquiries@etctax.co.uk

In one case, the developer of a Metaverse environment intends to allow individuals to purchase virtual real estate, represented by NFT’s. Plots of that real estate will consist of many small chunks represented by those NFT’s, so each plot will have multiple landlords. The plots will be ‘rented’ by individuals or businesses who will be able to ‘build’ on them, creating shops, advertising spaces or whatever else their imagination and the technology allow. This kind of virtual estate management is not new (e.g., SecondLife, developed by Linden Lab in 2003). The introduction of the blockchain adds another level of technological challenge as well as clear advantages and added functionality.

$9,999,9999

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‘Redomicile’ of Offshore Companies This article focuses on the legislative changes made over recent years with regard to offshore companies owning UK residential and commercial properties.

hilst the term ‘redomicile’ is currently used that is not strictly what happens to the offshore company. The company’s country of incorporation ( ‘seat’) – will remain the same – whether that is Channel Islands, BVI, Isle of Man or wherever. What essentially happens is that the assets of the offshore company (usually UK property) are transferred to a new UK limited company to enable the offshore company to be dissolved. Introduction The taxation of offshore companies has changed significantly over recent years, so much so that there are now virtually no advantages to holding UK properties in an offshore structure. More often that not the offshore company will itself be owned by an offshore trust which makes maintaining the overall offshore structure relatively expensive.

Clive Haworth Senior Manager clive.haworth@etctax.co.uk

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The taxation of offshore companies has changed significantly over recent years, so much so that there are now virtually no advantages to holding UK properties in an offshore structure.

Tax on rental profits Offshore companies have always been liable to UK tax on rental profits. Up until 5 April 2020 companies were liable to income tax on rental profits and from 6 April 2020 they are now liable to corporation tax. This inevitably added additional compliance costs as under the corporation tax regime accounts need to be submitted using HMRC-specific business language (known as iXBRL). Annual Tax on Enveloped Dwellings (ATED) ATED was introduced on 1 April 2013 and is primarily aimed at high value residential properties held within companies and occupied by non-UK domiciled individuals. In such circumstances the company is now subject to a fixed ATED charge, based on the value of the property within various bandings above £500,000. Where property is rented out commercially there is an exemption from ATED, although an annual tax return still has to be submitted claiming the exemption. Again, this is also an additional compliance cost. Capital gains From 1 April 2015, offshore companies are also liable to tax on any capital gains made on disposals of UK residential properties. The company can elect to either rebase the cost to the 1 April 2015 value or use original cost, if higher.

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From 6 April 2019 ‘indirect’ disposals – capital gains sale of shares in ‘property rich’ companies are also liable to tax. From 6 April 2019, gains on disposals of UK commercial properties are also liable to tax. Again, rebasing is available so it is only the gain arising after that date that is taxed. Inheritance Tax In most cases the shares in the offshore company will be privately held by family members (or a family trust). Legislation effective from 6 April 2017 means that the value of the company, to the extent that it relates to UK residential property, is now liable to Inheritance Tax. There are also anti-avoidance provisions to ensure that the ‘value’ is not artificially suppressed through the provision of associated loans. Note, however, that UK commercial property is not caught by these rules. Are there now any advantages in using an offshore company? The short answer is no. Some anonymity may be enjoyed and for celebrities and the like this may be important but for the vast majority it makes sense to migrate back to the UK as an offshore company owning UK residential property is now effectively in exactly the same position as its UK company counterpart. As mentioned previously, the additional administration costs of maintaining an offshore structure mean that is often desirable to relocate the property business to the UK. How to bring the structure onshore A typical step plan to bring the structure onshore would look something like this: 1. Change the management and control of the offshore company (“Offco”) to the UK by appointing UK directors. It is sometimes overlooked that Companies House need to be notified that there is now a UK establishment. 2. A new UK company (“Newco”) is formed with shareholdings that mirror the shareholdings in Offco. Usually the Newco will also have the same UK directors as Offco.

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3. There is a share-for-share exchange so that Offco becomes a wholly owned subsidiary of Newco. It is important that the reorganisation is a ‘mirror image’ to prevent Stamp Duty being payable on the value of the shares. 4. As there is now a UK group for capital gains tax and SDLT purposes, the properties can be transferred up to Newco without any tax or SDLT charges. 5. Once the properties have been transferred up, the offshore company can be dissolved. Note that the above summary is a very brief overview of the step plan and there will be many other related issues to consider, such as

Enjoying this article, but need more advice on any of the topics covered? To discuss how ETC can help with your tax questions call the team on 0161 711 1320 or email enquiries@etctax.co.uk

• It is important that all the above steps are properly documented (formal agreements, Board minutes, share certificates etc) and using lawyers fully au fait with these arrangements is money well spent; • It will of course be necessary to liaise with lawyers in the offshore company’s jurisdiction to check whether the proposed transactions do not create any tax issues there; • If there are any mortgages on the properties, potentially SDLT is payable and consideration should be given to as to whether the properties should be transferred outright or as a dividend in specie.

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The end result The overseas shareholders are left with a UK company owning UK properties at their original base cost. For capital gains tax purposes, the transfer between the companies will have taken place at no gain, no loss; there is usually no tax free uplift to market value on the transfer between companies - exceptionally there might be a tax free uplift if the transfer triggers a tax liability in the offshore jurisdiction. In our experience this is unlikely to apply in most cases. There is still a potential IHT exposure for the individual offshore shareholders based on the value of the shares they now hold in the UK holding company. Where the shares are held by an offshore trust there is also the prospect of Principal Charges (“Ten Year Charges”) being due in respect of residential property held since 6 April 2017.

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Splitting a company – demergers and HMRC clearance applications A demerger typically involves the splitting of a company’s business into two or more parts. There are many reasons why a company demerger may be desirable. Some of these examples include: • The shareholders of the business may wish to part ways and run their ‘parts’ of the business via separate entities. • The shareholders wish to incentivise employees of different service lines and for commercial purposes, view it is as more beneficial to do this under separate entities. • The business is serving separate market segments, and the directors believe that these would be best served under different management and via separate entities. There are typically three routes to achieving a demerger: - Statutory demerger - Reduction of share capital demerger - Liquidation demerger It is recommended that HMRC clearance is obtained prior to implementing a demerger, which is typically requested to obtain HMRC’s approval of the bona fide commercial purpose test in relation to the transaction.

Zeeshan Khilji Associate Director zeeshan.khilji@etctax.co.uk 12

The definition of chargeable payment is broad and catch scenarios where there is a sale of the demerged business post demerger and of the main reasons for undertaking the demerger is to dispose of the demerged business post demerger. Therefore, in scenarios where there is an impending sale of the business soon after the demerger, statutory demergers would not be a feasible option. Clearance request We recently came across a scenario whereby a client in the pharmaceutical industry had requested clearance from HMRC under the statutory demerger provisions. There was an intention to sell one of the pharmacies post demerger and one of the reasons for undertaking the demerger was to be able to sell the pharmacy separately and so a demerger of the pharmacies into separate companies was considered an appropriate commercial route to achieve this objective. Unsurprisingly, the clearance was refused by HMC under the chargeable payments rule set out above.

Statutory demergers provide a relatively simple method of separating a company’s activities. They allow shareholders the flexibility to split their trading activities and assets without generally crystalling tax liabilities. Statutory demerges have strict conditions associated with them, which can make them unattractive or indeed unfeasible in certain circumstances.

We carried out detailed analysis, redrafted and submitted a new clearance application to HMRC under a different set of provisions (in this case the reduction of share capital demerger rules) which HMRC accepted. We had to ensure that the mechanics of the transaction was amended in order to meet the detailed criteria of the demerger provisions, which did not prove to be too onerous for the client from a commercial viewpoint.

For example, one of the conditions associated with statutory demergers is that there must not be a ‘chargeable payment’ for five years following the demerger. These rules state that the demerger must not form part of an arrangement, one of the main purpose of which is the making of a chargeable payment.

Demergers are a complex area of tax law and it is important that specialist tax advice is sought, both from tax and legal viewpoints. Our specialist corporate tax team has many years of Big Four and Top 10 experience of advising on all aspects of demergers.

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EMI share option schemes and accelerated vesting

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Zeeshan Khilji discusses a peculiar point with regards to EMI share option schemes, which stresses the importance of obtaining specialist advice when implementing or making any changes to share schemes.

Background The EMI share option scheme allows employers to reward employees in a tax efficient manner, without causing a significant drain on the cash flow of the business. The primary benefit of the EMI scheme is that options over shares can be granted to key members of staff at today’s value, which can be agreed with HMRC in advance. Provided the exercise price (i.e. the price which the employee pays for the shares upon exercising the options) are at least equal to the market value of those shares at the date of grant, there are no income tax or NIC implications for the employee. Assuming the company grows in value and the employee stays with the company, the growth in value can usually be ‘protected’ from an employment income tax charge and would instead only be subject to capital gains, with the capital gains tax arising only when the employee subsequently disposes of their shares. Amendment to option agreement and accelerated vesting We recently came across a client scenario where, at the time of granting the share options, the vesting period for the share options was set at 5 years. There was however no provision for vesting in an exit event, such as a company sale. Therefore, in the event where the company was sold prior to the vesting date of 5 years, the option holders would not be able to exercise their share options. We were asked the question as to the tax implications of amending the option agreements, via a deed of variation, to include an accelerated vesting clause, which would enable the option holders to be able to exercise the option upon sale. Will this be deemed to be a disqualifying event?

Unfortunately, the legislation is unclear on the extent and nature of amendments to an option agreement which will constitute a disqualifying event. As such, we need to rely on guidance and case law. As expected, what constitutes a disqualifying event in terms of variation of EMI terms has historically been a grey area. However, HMRC’s stance on amending vesting periods is a lot clear now as this point was actually addressed in the Eurocopy Plc case where the courts agreed with HMRC that variation of EMI option rights by changing the vesting period meant it was a disqualifying event, meaning that the EMI options will cease. In order to ensure there are no adverse tax consequences for the option holders, they would need to exercise their options within 90 days of the variation. We also concluded that making such an amendment will result in a new grant of share options. As such, a new valuation would need to be agreed with HMRC. Our corporate tax team has specialist expertise in advising on the tax implications of share option schemes. If you would like to discuss tax efficient ways of incentivising employees, please get in touch.

EMI share option scheme allows employers to reward employees in a tax efficient manner

Zeeshan Khilji Associate Director zeeshan.khilji@etctax.co.uk 15

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Article by Keith Miller

VAT & Property: A Brief Overview

We are regularly asked to advise on property-related matters, both commercial and residential. It is interesting to note that we often hear the opinion that although there are lots of VAT issues and opportunities to consider in relation to commercial land and buildings, there isn’t that much going on when it comes to residential property, largely on the basis that apart from new build projects, everything’s VAT exempt. Although it may be true that most income generated from residential property is VAT exempt, it isn’t true to assume that there isn’t much to discuss in relation to residential properties. Read on to discover some common issues and opportunities that crop up in relation to land and buildings, including many that relate to residential properties. 17

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...freehold sale or long lease of a building that has been converted from non-residential to residential is subject to zero-rate VAT.

Is property-related income VAT exempt? The ‘default’ position is that the grant of a right to occupy land or buildings (sale or lease) is VAT exempt. However, there are numerous exceptions. For example, the grant of the freehold or a lease over 25 years (20 in Scotland) in a new residential building is subject to VAT at the zero-rate. This means that although no VAT is payable on the grant, it is taxable nonetheless is taxable, so related VAT costs can be recovered. The freehold sale of a ‘new’ non-residential building is subject to standard rate VAT. ‘New’ means that it was completed no more than 3 years before the freehold interest is granted. The sale or lease of non-residential land or buildings may also be subject to VAT at the standard-rate if the person making the supply has opted to tax the land. They would typically do this to enable recovery of VAT on related costs (that would otherwise be irrecoverable if the supply was VAT exempt). Please note that the option to tax can be a complex area so care should be taken when considering whether an option to tax should be made. An option to tax may also be ‘disapplied’ in certain circumstances, so care needs to be taken. The provision of parking facilities is also subject to standard-rate VAT (including the lease of land to be used for parking) as is the provision of storage facilities, and the provision of hotel and holiday accommodation.

Keith Miller Associate VAT Director keith.miller@etctax.co.uk 18

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Can I recover VAT incurred in relation to land related properties? The VAT recovery rules relating to land and buildings are no different in principle than normal VAT recovery rules, in that VAT can normally be recovered to the extent that the costs on which VAT is incurred relate to taxable supplies (made or intended). This is why it is important to understand whether a property or property transaction/ project will generate VAT exempt or taxable (zero or standard rate) income, or both. Although the usual VAT principles need to be followed, there is also a VAT scheme called the VAT Capital Goods Scheme that applies to certain types of property related capital expenditure where the VAT-bearing capital costs exceed £250k (e.g. acquisition, extension refurbishment costs). Although normal VAT rules apply to the initial recovery of any such VAT, the use of the asset has to be monitored over a 10-year period and adjustments to the initial VAT recovery may be required if the extent to which the land or buildings are used for taxable purposes changes over time. There are also ‘VAT clawback/payback’ rules that apply where VAT is recovered (or not recovered) on the basis of a particular intention, but that intention is never fulfilled, and the ‘new’ intention has a different VAT recovery profile to the original intention.

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Are there VAT Reliefs that can reduce VAT costs? Because many properties/property projects generate VAT exempt income, particularly residential projects, this will mean that VAT incurred on costs will typically be irrecoverable (either wholly or at least to some extent) and establishing the extent to which VAT costs can be recovered can be complex. This is why it’s important to be aware of VAT reliefs that may reduce (or eliminate in some cases) VAT on costs.

Enjoying this article, but need more advice on any of the topics covered? To discuss how ETC can help with your tax questions call the team on 0161 711 1320 or email enquiries@etctax.co.uk

The following are examples of services that are subject to 5% VAT rather than 20% VAT, and apply solely to residential properties: •C onstruction costs relating to the conversion of a non-residential building to residential •C onstruction costs relating to the conversion of an existing residential building resulting in a change in the number of dwellings •R efurbishment/renovation of an existing residential building that has not been occupied for 2 years

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It should also be noted that the freehold sale or long lease of a building that has been converted from non-residential to residential is subject to zero-rate VAT (so related VAT costs can be recovered in full, except VAT on ‘blocked goods’ such as kitchen appliances, curtains, etc). The sale of a residential building that has been renovated having not been used for residential purposes for over 10 years is also subject to the VAT zero-rate (treated the same as a conversion from non-residential to residential). The rules and conditions governing the application of these VAT reliefs can be complex and are often under-utilised by developers. This is often because contractors are unfamiliar with how VAT reliefs apply. Even where VAT reliefs and other VAT efficient structures are available, they will only typically apply if certain conditions are met, so it is essential that these conditions are identified and adhered to if a VAT relief is to be applied. VAT reliefs can be applied retrospectively too, so if a contractor has charged you too much VAT on past projects, it may still be possible to rectify this and obtain a VAT refund provided the VAT was charged within the last 4 years.

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At the end of April, ETC Tax welcomed 70 professionals to its first annual tax conference at Mere Golf and Spa Resort.

A tale of two chocolatiers

he conference, built around the theme of Succession (a poorly concealed doffing of a Kendal Roy style baseball cap to the eponymous HBO series) started with networking and a curry. Not a bad start! The ’WayStar’ RoyCos of the show. The conference was opened by Bernard Kelly. He told the attendees how he bought Benson for Beds as a turnaround in 1984. He built the company up from 8 to 140 stores before selling it to a public company. He is now the Chairman of Biramis business advisers.

Andy Wood Found & Director andy.wood@etctax.co.uk

Andy Wood started formal proceedings with a session on passing on the business to employees with a particular emphasis on Employee Ownership Trusts. Although this might be a useful tool for some clients, Andy highlighted some of the very real issues through his Willy Wonka case study (the first of the two great chocolatiers to dominate the day).

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Great content, great contacts and attendees

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Second, up to the oche was Zeeshan Khilji who have an energy-filled overview of the tax considerations when one is looking to sell the business to a third party purchaser. Zeeshan, who in a recent public confessional, revealed his passion for demergers did not disappoint here! Jon Davage, Head of a corporate at Bermans, joined us for a Q&A panel discussion on these two topics and explained his view of the current market conditions. After a short break for coffee and more networking, it was the turn of Alexander Wilson to provide an overview of some of the tax and non-tax considerations when thinking about transferring the business to the family. He looked at the use of structures including trusts and family investment companies. This was followed by another panel discussion where Harry Plunkett of Canaccord Genuity joined Alexander and Andy. After networking and drinks, we then moved into the relaxed, evening event. Here, Jo Fairley the co-founder of Green and Blacks chocolate provided an informative and entertaining review of her career to date. Following dinner, we drew the raffle winners, raising a total of £700 for Just Drop In. A great event and a massive thanks to Sarah Aston and the team for bringing this together. Well done and look forward to next year!

I loved the event and thought the day and presentations were excellent. A real success! 21

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In the spotlight: Harry Stuart Senior Digital Marketing Executive Harry's path to ETC Tax has seen him work as head of communications and partnerships for an online commercial property portal.

What is your position here at ETC Tax? My role here is Senior Digital Marketing Executive. What do you enjoy the most about your role? Every day is different especially being so new to the role. I’m enjoying the challenge, understanding the analytical data from the ETC Tax website. Putting together a strategy on how to improve the website for our users and clients. What is your area of expertise? Digital marketing and communications. What was the career path that brought you to ETC Tax? Before joining ETC Tax, my previous roles included working as Head of Communications and Partnerships for one of the UK’s largest commercial property portals. I’ve also been lucky enough to live in a few European countries.

Why a career in Digital Marketing? It’s about helping the company to grow and achieve yearly objectives continuously. Having a robust digital footprint enables continued growth. It will keep you on your toes as there are always new and innovative digital strategies waiting to be used. Tell us about how you made a difference in your role? Bringing all KPI data in-house. We are now making decisions based on the analytical data. When all the Digital tasks of the day are solved how do you spend your time? Either playing tennis, at the gym or Altrincham Market.

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“ It’s about helping the company to grow and achieve yearly objectives continuously. Having a robust digital footprint enables continued growth. ”

How do we get in touch with you if we need Tax Advice? Feel free to drop me an email at harry.stuart@etctax.co.uk or call the office on 0161 711 1320 23

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Bulletin:

The latest news round-up from the ETC team

The Report

A Week of Wellness More so than ever people are talking about mental health and the impact it can have. In support of mental health awareness week gratitude journals were put together as a positive mental exercise to start each day, reminding us to remain grounded and grateful for what we have. Team ETC also got involved in a few activities throughout the week co-ordinated by Lauren and Phoebe. There was Yoga, a buffet lunch, challenges such as ensuring people got their steps in for the day and we filled the positive jar with lots of encouraging notes, help yourself next time you are in the office!

Our monthly case review and activity report • A dvising on the property incorporation of a 17 property portfolio • E MI share scheme implementation for a fast growth start up • A large R&D claim for a company in the electronics sector • G rowth share and Family Investment Company planning for a family business • A reduction of share capital demerger of a veterinary practise • A dvising an overseas real investor on tax efficient property structuring in the UK •V aluation of a tech company in readiness for exit

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Did you know? 12 years ago, in May, bitcoin was used for the first time to buy a pizza costing 10,000 (about twenty quid)! As of 19 May 2022, this is amount is worth nearly £238m! Click here to find out more

We’re bringing Digital Marketing in house! Welcome to the business support team Harry. Harry has taken up the position of Senior Digital Marketing Executive. Harry has many years’ work experience across the digital marketing spectrum and is looking forward to helping ETC grow its digital footprint.

Promotion for Arjan Congratulations to Arjan who has been promoted to Assistant Tax Manager. Arjan has been with ETC Tax for almost 2 years and in that time he has worked hard to develop his knowledge and experience working alongside and supporting senior managers within the firm. A promotion that is well deserved, congratulations once again Arjan!

New Tax Manager joins the team! We are pleased to announce yet another great recruit within the tax team! Welcome to Amie Manchester who will take on the role as Tax Manager. Amie’s previous positions were at 2 of the ‘Big Four’ firms, and more recently she became a Chartered Tax Adviser. Amie is looking forward to helping individuals and businesses with their tax requirements. Welcome to ‘Team ETC’ Amie.