Technical articles and topic explainers

Finance Act 2023
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article summarises the changes made by the UK Finance Act 2023.

Summary of available articles
An overview and synopses of the latest technical articles to support you in your studies.

Corporation tax 
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article considers the taxation of a company as it begins trading, acquires an additional business, and eventually invests overseas. It sets out the commercial decisions taken by the company and its shareholders at the different stages in the company’s development and summarises the tax implications of those decisions.

Corporation tax – groups and chargeable gains 
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article begins by briefly summarising the rules relating to both group relief groups and capital gains groups. It then goes on to consider various issues relating to capital gains groups that could be introduced in an exam question. It does not include comprehensive explanations of the rules but assumes a reasonable knowledge.

Corporation tax – group relief 
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article begins by briefly summarising the rules relating to both group relief groups and capital gains groups. It then goes on to consider a number of group relief tax planning issues that could be introduced in an exam question. It does not include comprehensive explanations of the rules but assumes a reasonable knowledge.

Inheritance tax and capital gains tax
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article considers the occasions where both capital gains and inheritance taxes are relevant to a transaction. It also features illustrations of some issues that need to be considered when giving advice in the context of the exam.

International aspects of personal taxation
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article begins with some basic rules, an understanding of which enables the particular areas of tax affected by an individual coming to, or leaving, the UK to be identified. It then goes on to review those areas in some detail, and provides a clear set of questions to ask in order to determine an individual’s liability to UK taxes. Finally, it deals briefly with the impact of double tax relief and treaties.

Taxation of the unincorporated business
The new business
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article looks at the issues relating to a new business including the choice of business vehicle and the first years of trading.

Taxation of the unincorporated business
The existing business
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article looks covers some of the issues relating to extraction of profits, change of accounting date and the final years of a business.

Trusts and tax
Relevant to those sitting ATX-UK in June, September or December 2024 or March 2025
This article has been written because the taxation of trusts and the transfers of assets to and from trustees is a complicated area of the UK tax system. Accordingly, there is a need to set out the rules that may be examined and those areas where knowledge is not required. 

Topic explainer video: VAT on land and buildings
In this video, expert tutor Aileen Edgar looks at the topic of 'VAT on land and buildings' (YouTube)

Topic explainer video: Capital gains tax vs inheritance tax
In this video, expert tutor Aileen Edgar looks at the topic of 'Capital gains tax vs inheritance tax' (YouTube)

Topic explainer video: VAT partial exemption
In this video, expert tutor Aileen Edgar unpacks the topic of 'VAT partial exemption' (YouTube)

Topic explainer video: Arising Vs Remittance Basis
In this video, expert tutor Aileen Edgar unpacks the topic of 'Arising Vs Remittance Basis' (YouTube)

Topic explainer video: Incorporation
In this video, expert tutor Helen Forster unpacks the topic of 'Incorporation' (YouTube)

Topic explainer video: Company purchase of own shares
In this video, expert tutor Helen Forster unpacks the topic of 'Company purchase of own shares' (YouTube)

Topic explainer video: Chargeable gains - takeovers
In this video, expert tutor Helen Forster unpacks the topic of 'Chargeable gains - takeovers' (YouTube)

Topic explainer video: EIS & SEIS
In this video, expert tutor Aileen Edgar unpacks the topic of 'EIS & SEIS' (YouTube)

Topic explainer video:Tax planning for couples
In this video, expert tutor Aileen Edgar unpacks the topic of Tax planning for couples' (YouTube)

Topic explainer video:How to earn professional skills marks in ATX
In this video, expert tutor Aileen Edgar demonstrates how to earn professional skills marks in ATX (YouTube)

Understanding the four-year rule for dividends between Cyprus tax resident companies 
Relevant to ATX-CYP
This article considers the tax treatment of the four-year rule which, when applied, does not allow for the exemption from the imposition of special defence contribution (SDC) on dividends between Cyprus tax-resident companies.

Back-to-back loans
Relevant to ATX-CYP
This article explains the tax treatment of back-to-back loans, as well as an amendment relating to the deductibility of loan interest when the loan is used to purchase shares in a 100% subsidiary of a Cyprus company.

The pitfalls of interest deduction claims by corporate taxpayers
Relevant to TX-HKG and ATX-HKG
This article is relevant to candidates preparing to sit TX-HKG and ATX-HKG. It aims to explain, in layman terms as far as possible, the Hong Kong tax rules and practice surrounding the claims for interest deductions by corporate taxpayers. It should be read in conjunction with The pitfalls of interest deduction claims by individual taxpayers.

The pitfalls of interest deduction claims by individual taxpayers
Relevant to TX-HKG and ATX-HKG
This article is relevant to candidates preparing to sit TX-HKG and ATX-HKG. It aims to explain, in layman terms as far as possible, the Hong Kong tax rules and practice surrounding the claims for interest deductions by individual taxpayers.

The boat
Relevant to ATX-IRL
This article on pensions is relevant to ATX-IRL candidates and is based on the legislation in force as at 30 September 2021, for the 2022 exams.

Pensions
Relevant to ATX-IRL
This article is relevant to ATX-IRL candidates and is based on the legislation in force as at 30 September 2022, for the 2023 exams.

Trusts
Relevant to ATX-IRL
This article article is relevant to ATX-IRL candidates and is based on the legislation in force as at 30 September 2022.

The Spice Girls
Relevant to ATX-IRL
Residency rules are many and complex. Tax lecturer Paula Byrne illustrates some of the intricacies of these rules with a little help from her favourite girl band.

Share-based remuneration
Relevant to ATX-IRL
Share-based remuneration schemes are used by employers – mainly public companies – to reward employees and ensure their continued commitment. This article explains the tax treatment of five different types of share-based remuneration and is relevant to candidates preparing to sit the ATX-IRL exam.

Revenue’s Code of Practice for Compliance Interventions 2022
Relevant to TX-IRL and ATX-IRL
This article is based on Revenue’s Code of Practice for Compliance Interventions 2022 (the Code), which is effective from 1 May 2022 and is relevant for candidates sitting TX-IRL and ATX-IRL from June 2023 onwards.

Goods – the place of supply rules
Services – the place of supply rules
Relevant to ATX-MLA
These two articles aim to help ATX-MLA candidates in their understanding of the value added tax (VAT) place of supply rules.

Transfer pricing rules
Relevant to ATX-MLA
During 2022, Malta introduced a formal transfer pricing framework by means of Legal Notice 284 of 2022 (the Transfer Pricing Rules, ‘TPR’), enacted by the Minister for Finance under the authority of article 51A of the Income Tax Act (‘ITA’). The TPR are included in the 2024 syllabus for ATX-MLA and are examinable from June 2024 onwards.

ATAD controlled foreign company rules
Relevant to ATX-MLA
During 2018, Malta transposed into Maltese tax legislation the provisions of Council Directive 2016/1164 issued on 12 July 2016 (commonly referred to as Anti-Tax Avoidance Directive, ATAD I). Some of the provisions of ATAD I and II are included in the ATX-MLA syllabus and are examinable from June 2020 onwards. The first article in a three-part series explains the controlled foreign company (CFC) rules.

ATAD GAAR and exit tax rules
Relevant to ATX-MLA
The three-part series continues with an explanation of the general anti-abuse rules (GAAR) and exit tax.

ATAD interest limitation rules
Relevant to ATX-MLA
The three-part series concludes with an explanation of the interest limitation rules.

Consolidated group rules 
Relevant to ATX-MLA
This article explains the main provisions of the Consolidated Group (Income Tax) Rules and with a view to guiding ATX-MLA candidates in respect of the examining team’s expectations on the topic

VAT treatment of call-off stock
Relevant to ATX-MLA
The VAT treatment of call-off stock is included in the ATX-MLA syllabus and is examinable from June 2021 onwards.

Notional interest deduction (NID) rules
Relevant to TX-MLA and ATX-MLA 
During 2017, Malta introduced a new NID regime, which is effective from the 2018 year of assessment. The NID is designed to align the tax treatment of the cost of equity with that of the cost of debt. 

Stamp duty
Relevant to ATX-MYS
The content of this article is based on current legislation relating to stamp duty, with coverage restricted to syllabus item A6.

Earnings stripping rules
Relevant to ATX-MYS
This article is based on current legislation relating to the anti-avoidance provision of interest restriction under the earnings stripping rules and excludes any reference to subject matters (such as financial services, insurance, Islamic financing, property development and construction), which are not included in the ATX-MYS syllabus.

Transitioning into sales tax and service tax – clarifying the confusion
Relevant to ATX-MYS
The article is relevant for candidates preparing for FTX-MYS Foundations in Taxation as well as providing a good foundational read for candidates taking the TX (MYS) and ATX (MYS) exams. The article is based on prevailing laws as at 31 March 2019.

Advanced aspects of service tax – management services
Relevant to ATX-MYS
This article addresses the advanced aspects of service tax in relation to the provision of management services.

Real Property Gains Tax
Relevant to ATX-MYS
This three-part article discusses the provisions relating to the general aspects of the Real Property Gains Tax Act 1976 (RPGT Act) as at 31 March 2019. It also looks at the provisions in the act that directly impact the RPGT liability, as well as compliance requirements, and provisions relating to special aspects.

Labuan: a comprehensive look (updated)
Relevant to ATX-MYS
This article aims to pull together various laws and successive development in the relevant laws relating to entities in Labuan, an island in the South China Sea established in 1990 as an international offshore financial centre (IOFC) and rebranded in recent years as an international business financial centre (IBFC).

Tax incentives for research and development in Malaysia
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967 (the Act) and the Promotion of Investments Act 1986 (PIA) to promote candidates' understanding of the interplay of the income and deductions relating to the various R&D activities or expenditure. While reading this article, candidates are expected to refer to the relevant provisions of the Act, the PIA, and Public Ruling 5 of 2004 as amended in 2008.

Pioneer status, investment tax allowance, and reinvestment allowance
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967, and the Promotion of Investments Act 1986 (PIA). While reading this article, candidates are expected to refer to the relevant provisions of the Act and PIA, as amended.

Tax treatment of interest income and interest expense
Relevant to ATX-MYS
This article collates and discusses the provisions in the Income Tax Act 1967 to assist candidates with understanding the more intricate issues relating to interest income and interest expense. While reading this article, candidates are expected to refer where necessary to the relevant provisions of the Act and the Public Ruling 9 of 2015.

Miscellaneous receipts
Relevant to ATX-MYS
This article is relevant to section A3 of the syllabus, the nature and taxability of miscellaneous receipts including sums arising on disposal of, or otherwise dealing with, tangible and intangible assets, grants, subsidies, donations and contributions, awards, scholarships, and gifts and inheritances.

Anti-avoidance provisions in Malaysia
Relevant to ATX-MYS
This article is an updated version of the article published in November 2011. It is relevant to candidates preparing for ATX-MYS and the laws referred to are those in force at 31 March 2021. It discusses only the provisions in the Income Tax Act 1967 (the Act). 

Employee share schemes
Relevant to ATX-MYS
The purpose of this article is to discuss the Malaysian income tax implications arising from the provision of employee share schemes, focusing on Employee Share Option Schemes and Employee Share Purchase Plans.

Basis periods
Relevant to ATX-MYS
The focus of this article is the determination of basis periods for a company on the commencement of operations and when there is a change of accounting date.

Taxation of individuals – advanced aspects
Relevant to ATX-MYS
This article has been updated to prevailing tax laws as at 31 March 2016. 

Taxation of trusts in Malaysia
Relevant to ATX-MYS
A comprehensive focus on the taxation of trusts in Malaysia, including an outline on what trusts are, aspects of tax treatment of trusts and trust beneficiaries, and tax computation of trusts.

Double tax agreements
Relevant to ATX-MYS
The main features of double tax agreements and an explanation of some common terms and catchphrases used in connection with treaties.

The export incentives regime in Malaysia
Relevant to ATX-MYS
This article is based on current legislation relating to the export of manufactured products and agricultural produce, and does not purport to trace successive development.

Enterprise Innovation Scheme (EIS)
Relevant to ATX-SGP
In the 2023 Budget, the Enterprise Innovation Scheme (EIS) was introduced by the Singapore government to encourage businesses to engage in research and development (‘R&D’), innovation and capability development activities. This article highlights some of the salient features of EIS, which candidates taking ATX-SGP should take note of. 

Relief options for current year unabsorbed capital allowances and trade losses
Relevant to ATX-SGP
This article examines the choice between current and enhanced carry-back relief for current year unabsorbed capital allowances and trade losses and the interaction between the carry-back relief system and group relief for companies.

Key Budget 2020 proposed tax changes
Relevant to ATX-SGP
This article focuses on the specific tax measures that were introduced in the main Singapore Budget 2020.

Recent changes to the stamp duty regime in Singapore
Relevant to ATX-SGP
The stamp duty regime in Singapore has undergone some significant changes in recent years and this article takes stock of these changes.

Key Budget proposed tax changes for businesses
Relevant to ATX-SGP
Singapore's finance minister delivered a futuristic Budget statement for the Financial Year 2018 (Budget 2018) in February 2018. This article highlights the significant tax changes announced for businesses.

Emigration and taxation
Relevant to ATX-ZAF
This article is intended to assist candidates with identifying the South African tax consequences of emigration to or from South Africa. The intention is not to provide an in-depth discussion, but to draw attention to the various possible tax issues. You should refer to your study text to complement and integrate the aspects covered in this article.

New exam format from June 2023 and exam technique for ATX-IRL
The aim of ATX-IRL is to ensure that candidates can provide individuals and businesses with the information and advice they require regarding the impact that the major Irish taxes may have on their financial decisions and situations.

New exam format from June 2023 and exam technique for ATX-MLA
The aim of this short article is to offer candidates some tips which they should find useful in order to achieve success in this exam. 

New exam format from December 2023 and exam technique for ATX-MYS
This article provides guidance on the new format of the ATX-MYS exam applicable from December 2023, and some advice on good exam technique and best exam practice.

Making the best use of the tax tables in your ATX-UK exam
When preparing for the ATX-UK exam, it is essential that you become familiar with the reference information – commonly known as the ‘tax tables’ – provided to you within the computer-based exam (CBE) software, and that you are able to make the best use of this when answering questions.

Stepping up from TX-CYP to ATX-CYP
ATX-CYP is directly underpinned by TX-CYP. Knowledge and understanding of the technical content of TX-CYP is therefore vital for candidates to be successful at ATX-CYP.

Stepping up from TX-UK to ATX-UK
ATX-UK is directly underpinned by TX-UK. Knowledge and understanding of the technical content of TX-UK is, therefore, vital if candidates are to be successful at ATX-UK.

How to approach Advanced Taxation
To study Advanced Taxation effectively you need to understand the nature of the exam and what you will be asked to do.

Passing Strategic Professional exams
This article looks at what you can do to improve your chances of passing ACCA’s Strategic Professional exams.

Passing the ATX-UK exam
This article sets out the two issues which are relevant to success in the ATX-UK exam: technical knowledge and exam technique.

ATX – examiner's approach (updated May 2023)
The aim of the exam, its structure and format.

Exam technique and fundamental technical issues
This article outlines two important aspects of examination technique and a number of fundamental technical areas that need to be mastered. This article is relevant to students who are beginning their studies and also those for whom the exam is imminent.

Guidance on answering Section A questions for P6 (UK)
An outline of some key advice for students on answering the two questions in Section A of P6 (UK).

Improving your performance
This article, which is relevant to all those preparing to sit P6 (UK), looks at the four aspects of exam technique: reading the question, satisfying the requirements, thinking, and time management. It also provides an overview of useful P6 (UK) technical articles.