FINANCE BILL/FINANCE ACT UPDATE. Robert Jamieson MA FCA CTA (Fellow) TEP 18 October 2017
|
|
- Jeremy Lawson
- 5 years ago
- Views:
Transcription
1 FINANCE BILL/FINANCE ACT UPDATE Robert Jamieson MA FCA CTA (Fellow) TEP 18 October 2017
2 DIVIDENDS Dividend tax rates unchanged for 2017/18. But dividend allowance reduced to 2,000 for 2018/19 onwards.
3 TRADING AND PROPERTY ALLOWANCES W.e.f. 6 April 2017, individuals do not have to pay income tax on trading and property income of up to 1,000 in each case. This helps those who do sell items on ebay or who rent out car parking spaces at home on sporting occasions such as Wimbledon. No need to determine allowable expenses.
4 TRADING AND PROPERTY ALLOWANCES (CONT) Partial relief where income exceeds 1,000 use 1,000 instead of actual allowable expenditure. Needs election usual time limit. Individual can also elect not to take advantage of this relief only likely to be necessary where there is loss. Partnership trades are excluded.
5 TRADING AND PROPERTY ALLOWANCES (CONT) If individual has 2 or more sources of trading income, he can decide how to split his 1,000 between each trade. But cannot thereby create loss from any of his sources. Anti-avoidance for employers and close companies.
6 TRADING AND PROPERTY ALLOWANCES (CONT) In context of property allowance, distributions from REITs and income representing rent-a-room receipts do not qualify for this relief. Also property landlords cannot use 1,000 facility if they have non-deductible interest costs (eg. because of changes which took effect on 6 April 2017).
7 OPTIONAL REMUNERATION ARRANGEMENTS Salary sacrifice schemes with benefits in kind can offer useful income tax and NIC savings. New legislation in Sch 2 FA 2017 attempts to stop most of these advantages. Unfortunately, latest changes are not just restricted to salary sacrifice schemes they also impact on flexible benefit arrangements.
8 OPTIONAL REMUNERATION ARRANGEMENTS (CONT) 2 types of optional remuneration arrangement : Type A; and Type B. In either of these cases, taxable value will be higher of: existing taxable value of benefit; or salary foregone.
9 OPTIONAL REMUNERATION ARRANGEMENTS (CONT) Tax charge will nearly always be second of these 2 options. This anti-avoidance legislation will not apply to: pension scheme contributions from employer; employer-provided pensions advice; employer-provided childcare;
10 OPTIONAL REMUNERATION ARRANGEMENTS (CONT) cycle-to-work schemes; provision of ultra-low emission vehicles; and benefits related to termination of employment. Takes effect from 6 April 2017, but grandfathering will ensure that schemes in place before 6 April 2017 are protected for 1 further year.
11 OPTIONAL REMUNERATION ARRANGEMENTS (CONT) And, for arrangements involving cars, vans, fuel, living accommodation and school fees, transitional protection continues until 5 April Transitional protection will be lost if terms of pre-6 April 2017 arrangement are varied or renewed on or after that date. Further guidance now found in HMRC s Employment Income Manual.
12 OPTIONAL REMUNERATION ARRANGEMENTS (CONT) Recent announcement about company cars provided via salary sacrifice scheme. Impact of new rules will clearly be greater for benefits with low statutory value or where benefit is otherwise exempt. Hostile reception for Sch 2 FA 2017.
13 ASSETS MADE AVAILABLE TO EMPLOYEES Special rules for determining cash equivalent of benefit in kind in respect of cars and beneficial loans. Other assets are subject to 20% annual value charge in S205 ITEPA On strict interpretation, employees are taxed as if asset is made available for whole tax year, even if it is only available for part of year or is being shared.
14 ASSETS MADE AVAILABLE TO EMPLOYEES (CONT) No provision for apportioning such benefits, despite case law decisions like Westcott v Bryan (1969). Also see guidance in Paras EIM21634 and EIM21635 of Employment Income Manual. S8 FA 2017 introduces provisions which calculate adjusted cash equivalents for 2017/18 onwards where asset is not available for employee s private use.
15 ASSETS MADE AVAILABLE TO EMPLOYEES (CONT) Deduction to be made from benefit charge for any day when asset is unavailable for private use because it: is not in fit condition; is undergoing repair or maintenance; or is shared with another employee.
16 EMPLOYER-FINANCED PENSIONS ADVICE New income tax exemption where relevant pensions advice is provided for employee. Exemption is limited to 500 per tax year. This covers advice not just on pensions but also on other financial and tax issues relating to pensions. Replaces previous limit of 150 see SI 2002/205.
17 EMPLOYER-FINANCED PENSIONS ADVICE (CONT) If individual has 2 or more employments, 500 exemption applies separately to each. Benefit must normally be available to all employees cannot be given to, say, senior staff only. Let-out for certain groups of employees on grounds of age or ill-health. Takes effect for 2017/18 onwards.
18 EMPLOYER-FINANCED PENSIONS ADVICE (CONT) Exemption was recommended as part of outcome of recent Financial Advice Market Review involving HM Treasury and Financial Conduct Authority.
19 TIME LIMIT FOR MAKING GOOD This refers to situation where employee makes payment in return for benefit from his employer. Payment reduces taxable value of benefit on -for- basis most commonly it arises on account of stipulation on part of employer. Thought necessary to have fixed date by which benefits must be made good.
20 TIME LIMIT FOR MAKING GOOD (CONT) F(No2)B 2017 has therefore set 6 July following end of relevant tax year as latest date for this purpose. This applies for 2017/18 onwards.
21 LEGAL EXPENSES Cost of legal advice paid for by employer was previously only deductible if employee (or former employee) had had allegations made against him in his capacity as employee. No longer necessary for employee to be on receiving end of such allegations for example, employee might be having to give evidence before a public hearing.
22 LEGAL EXPENSES (CONT) If legal advice and support is required, it will now be possible to claim deduction. Similarly, it was felt to be unfair that individuals in receipt of termination payments could only have access to allowable deduction if they paid their legal costs first this has also changed. Amendments take effect for 2017/18 onwards.
23 TERMINATION PAYMENTS Recent consultation about tax and NIC treatment of termination payments. W.e.f. 6 April 2018, Government will be: retaining 30,000 exemption; continuing with unlimited employee NIC exemption; making all payments in lieu of notice (PILONs) subject to tax and NICs;
24 TERMINATION PAYMENTS (CONT) treating any other contractual payment as earnings; aligning rules for income tax and NICs so that employer NICs are chargeable on payments in excess of 30,000; removing foreign service relief; and confirming that injury exemption does not extend to payments for injured feelings.
25 TERMINATION PAYMENTS (CONT) Tax consequences will no longer depend on how employment contract is drafted or on whether payments are structured to represent some other form of arrangement (eg. payment for damages). Feelings about these provisions are: annoyance that these amendments will complicate law rather than simplify it;
26 TERMINATION PAYMENTS (CONT) disappointment that non-contractual PILONs will no longer fall within 30,000 exemption; surprise about decision to impose employer NICs; concern that introduction of NICs will cause confusion among employers; and
27 TERMINATION PAYMENTS (CONT) unease that imposition of NICs will make employers more inclined to reduce value of termination packages. And should foreign service relief really be abolished? Abolition is going ahead, but with small relaxation in FB 2018.
28 PENSIONS Individuals who have already flexibly accessed their money purchase pension schemes following changes introduced in 2015 are subject to modified AA test known as money purchase annual allowance (MPAA). MPAA was originally set at 10,000. This was primarily to deter recycling.
29 PENSIONS (CONT) Government now believe that this limit was too generous w.e.f. 6 April 2017, MPAA has been reduced to 4,000. Unused MPAA cannot be carried forward (unlike AA). 10% special deduction abolished for foreign pensions paid to UK-resident individuals on or after 6 April 2017 (Sch 3 FA 2017).
30 DEDUCTION OF INCOME TAX FROM INTEREST Because of FA 2016, 95% of all taxpayers who receive interest no longer have to pay tax on it. Following consultation, no income tax deducted at source from interest paid by: investment trusts; open-ended investment companies; and authorised unit trusts.
31 DEDUCTION OF INCOME TAX FROM INTEREST (CONT) This latest change takes effect on 6 April Also no tax deduction at source from interest paid to investors in peer-to-peer lending. See Sch 5 FA 2017.
32 EIS AND SEIS CHANGES For shares issued on or after 5 December 2016, EIS and SEIS rules amended to allow companies to have shares with rights for conversion or exchange at later stage into shares of different class. However, conversion or exchange should not take place during qualifying period (normally next 3 years).
33 SOCIAL INVESTMENT TAX RELIEF Original 5-year time limit for qualifying SITR investment extended by further 2 years, ie. up until 5 April SITR investor must be independent of social enterprise, ie. he must hold no other shares or debentures in social enterprise.
34 SOCIAL INVESTMENT TAX RELIEF (CONT) New stipulation that there must be no disqualifying arrangements, ie. no arrangements entered into with main purpose of securing any of following venture capital reliefs: SITR; EIS/SEIS/VCT relief; and share loss relief.
35 SOCIAL INVESTMENT TAX RELIEF (CONT) Uprated investment limit of 1,500,000 for any social enterprise. Employee limit is fewer than 250 full-time equivalent employees. Social enterprise must be in sound financial health at time of investment. Several new prohibited activities (eg. leasing). These all have effect from 6 April 2017.
36 BUSINESS INVESTMENT RELIEF BIR allows remittance basis taxpayers to bring in overseas income and gains without paying tax, provided they use money to make commercial investment in company. Needs claim. Qualifying investment can be made directly or indirectly this must be done within 45 days.
37 BUSINESS INVESTMENT RELIEF (CONT) Originally, BIR investment covered: subscription of new shares or securities; or making of loan. Company (known as target company ) had to be: eligible trading company; or eligible stakeholder company; or
38 BUSINESS INVESTMENT RELIEF (CONT) eligible holding company. No requirement for target company to be UK-incorporated. Investment must always be in private company (with no shares listed on recognised stock exchange). LLPs and other non-corporate structures are excluded. 2-year start-up rule for trading companies.
39 BUSINESS INVESTMENT RELIEF (CONT) 2 points to note: property letting counts as commercial trade; and at least 80% of company s activities must be trading (measured by reference to turnover). At time of investment, individual must not obtain related benefit (ie. any benefit attributable to making of investment).
40 BUSINESS INVESTMENT RELIEF (CONT) Director s fees and normal benefits in kind are OK. No monetary limits to remittance or size of investment. Relief is not restricted to UK-resident companies nor does company s business have to be carried on wholly or mainly in UK. All types of trade qualify (cf. EIS relief).
41 BUSINESS INVESTMENT RELIEF (CONT) No embargo on investor working for his company indeed, company can be family concern. Clawback of relief in certain circumstances (eg. sale or abnormal extraction of value), but can be set aside by appropriate mitigation steps. Changes in F(No2)B 2017 to make BIR more attractive (all w.e.f. 6 April 2017):
42 BUSINESS INVESTMENT RELIEF (CONT) BIR to be allowed on acquisition of existing shares; start-up period for company planning to trade extended from 2 to 5 years; company can be both trading and stakeholder entity (ie. hybrid); company which is member of LLP is not regarded as carrying on LLP s trade;
43 BUSINESS INVESTMENT RELIEF (CONT) extraction of value rule will only be treated as having been breached if abnormal benefit is received in circumstances attributable to taxpayer s investment; and longer grace period allowed where company fails to satisfy 5-year start-up time limit.
44 APPROPRIATION TO TRADING STOCK Where chargeable asset is appropriated for use as trading stock, trader is deemed to have sold asset for current MV. Potential difficulty of collecting CGT dry tax charge. Election under S161(3) TCGA 1992: no gain or loss; but MV of asset in trading accounts is adjusted.
45 APPROPRIATION TO TRADING STOCK (CONT) Converts capital gain into trading profit but is this always desirable? Time limit for making election. Hitherto, election has also been valid where there was allowable loss effect was to replace loss with more flexible trading deduction. Widely used planning point in recent times for, eg. property developers.
46 APPROPRIATION TO TRADING STOCK (CONT) However, election facility removed for appropriations to trading stock made on or after 8 March 2017 where loss arises. Loss now has to remain as capital item. Election can still be made for chargeable gains.
47 EMPLOYEE SHAREHOLDER STATUS ABOLISHED Favourable tax treatment for employee shareholder shares brought in 4 years ago has been abolished for schemes set up on or after 1 December In FA 2013, employees were granted CGTfree shares worth up to 50,000 in return for waiving normal employment rights. Income tax and NICs not chargeable on first 2,000 of share value received.
48 EMPLOYEE SHAREHOLDER STATUS ABOLISHED (CONT) Tax advisers initially sceptical about idea. But it was widely used, for example, by private equity firms. Hence lifetime limit of 100,000 placed on CGT exemption by S88 FA All tax advantages for employee shareholder status have been removed for schemes launched on or after 1 December 2016.
49 EMPLOYEE SHAREHOLDER STATUS ABOLISHED (CONT) However, arrangements set up before 1 December 2016 are still OK shares can be sold free of CGT (up to 100,000 limit). Note own share purchase change sale proceeds no longer treated as automatic capital receipt. See Ss12 14 FA 2017.
50 ENVELOPED UK PROPERTY Non-UK domiciliaries are chargeable to IHT on UK-situated property this rule applies, regardless of individual s residence status. Standard practice for such individuals: hold UK residential property through overseas company (or similar vehicle). This gives rise to excluded property, but potential exposure to ATED.
51 ENVELOPED UK PROPERTY (CONT) W.e.f. 6 April 2017, Government are bringing UK residential properties within charge to IHT where they are held in overseas structure. Such property is to be removed from definition of excluded property in Ss6 and 48 IHTA No difference whether overseas structure is owned by individual or trust.
52 ENVELOPED UK PROPERTY (CONT) Shares in close overseas company will no longer constitute excluded property to extent that value of any interest is attributable, directly or indirectly, to UK residential property. Similar rules for non-uk domiciliaries who are partners in overseas partnerships holding residential property in UK.
53 ENVELOPED UK PROPERTY (CONT) Normal IHT chargeable event legislation will bite. Limited de minimis exemption less than 5% interest (by value). These changes do not affect other UK situs assets owned by offshore entities only residential property is caught.
54 ENVELOPED UK PROPERTY (CONT) Definition of UK residential property is wide no minimum monetary threshold and no special reliefs for main residence or rental properties. Government have decided to go with definition in FA 2015 for non-uk residents rather than that applying for ATED. This covers any property suitable for use as dwelling (+ construction/adaptation).
55 ENVELOPED UK PROPERTY (CONT) List of exceptions. But what happens if residential property has previously been used for commercial purposes? Just and reasonable apportionment is not considered to be appropriate. Originally, Government planned to introduce rule adapted from IHT business relief legislation.
56 ENVELOPED UK PROPERTY (CONT) Full value would be caught if it had been dwelling at any time within last 2 years. But this idea has been dropped. Only relevant factor = status of property at time of chargeable event. Apportionment will, however, be needed where there is duality of use, eg. flat above shop premises.
57 ENVELOPED UK PROPERTY (CONT) Valuation: use value of holding in overseas entity, and not value of underlying property itself. Valuation: where overseas entity owns other assets in addition to UK residential property, make adjustment to ensure that only value deriving from UK residential property interest is caught.
58 ENVELOPED UK PROPERTY (CONT) With debts, they can be offset against value of UK residential property, but, where there are other types of asset, liability must be allocated across all assets (in proportion to MVs). This applies even if debt is specifically secured on UK residential property. Illustration.
59 ENVELOPED UK PROPERTY (CONT) In addition, there will be exposure to IHT where: there is relevant loan ; money or money s worth is used as security, collateral or guarantee; or interest of shareholder or partner is directly or indirectly attributable to loan or collateral for it.
60 ENVELOPED UK PROPERTY (CONT) Relevant loan refers to situation where money or money s worth is made available to finance: acquisition of UK residential property; maintenance or enhancement of UK residential property; or acquisition of interest in company or partnership where funds are used for UK residential property.
61 ENVELOPED UK PROPERTY (CONT) Term is not limited to loans between connected parties. Can these rules create duplicate liabilities? Illustration. Anti-avoidance provisions are aimed at catching situations where, on or after 6 April 2017, UK residential property is sold or relevant loan is repaid.
62 ENVELOPED UK PROPERTY (CONT) But only if this takes place within 2 years prior to chargeable IHT event. This applies to sales of interests in company or partnership, and not to disposals of underlying UK property. Watch 2-year run-off period. HMRC are keen that extension of IHT to enveloped properties should not be circumvented.
63 ENVELOPED UK PROPERTY (CONT) Introduction of TAAR: arrangements will be disregarded if main purpose is to secure tax advantage. Does this mean that TAAR can only apply to transactions entered into on or after 6 April 2017? No transitional reliefs to come collapse structures now? Collection of tax.
64 DEEMED DOMICILE Widening of scope of deemed domicile w.e.f. 6 April Applies for income tax, CGT and IHT. New terminology: anyone born in UK with UK domicile who is UK-resident but is at present non-uk domiciled = formerly domiciled resident (FDR); and
65 DEEMED DOMICILE (CONT) anyone who has been resident in UK for at least 15 out of last 20 tax years = long-term resident. Both categories are classified as deemed domiciled but only for tax purposes. Circumstances of parents do not impact on children. FDRs are unable to access remittance basis for income tax and CGT.
66 DEEMED DOMICILE (CONT) However, remittance basis will still apply for pre-2017/18 foreign income and gains remitted on or after 6 April Anti-avoidance legislation FDRs, where they are settlors, will have income and gains of offshore trusts attributed to them on arising basis. Reporting requirements for trustees of offshore trusts.
67 DEEMED DOMICILE (CONT) FDRs caught by IHT on worldwide basis. Similarly, any trust of which FDR is settlor will be denied excluded property status as long as settlor remains resident in UK. Special IHT period of grace relaxation: new IHT rule will only bite where FDR: is resident in UK; and was UK-resident for at least 1 out of last 2 tax years.
68 DEEMED DOMICILE (CONT) When determining 10-year anniversary charges, key factor is whether settlor was deemed domiciled at 10-year anniversary date if so, look at number of quarters in last 40 when he was deemed domiciled. No grandfathering for excluded property trusts set up before 8 July FDR will lose deemed domicile in first tax year of non-uk residence, provided he:
69 DEEMED DOMICILE (CONT) retains his foreign domicile under general law; and has not become deemed domiciled by virtue of long-term residence. It does not matter how many years FDR has been abroad before he re-establishes residence in UK. For long-term residents, there is 1 transitional exception where:
70 DEEMED DOMICILE (CONT) individual is not resident in UK for tax year in question; and there is no tax year beginning after 5 April 2017 and preceding tax year in question when he was UK-resident. Anomaly will it be sorted out? No. Remittance basis can continue for those with less than 2,000 of unremitted foreign income and gains.
71 DEEMED DOMICILE (CONT) Remittance basis charges of 30,000 and 60,000 are remaining in place. But 90,000 charge became obsolete on 6 April What happens if individual is both FDR and long-term resident? FDR rules take precedence. For long-term residents, necessary to reconsider relief for capital losses.
72 DEEMED DOMICILE (CONT) Hitherto, UK-resident non-uk domiciliary who wants to access remittance basis has had to choose either to: forfeit entitlement to relief for foreign capital losses; or make irrevocable capital loss election. This latter allows relief for all his capital losses, but in special prescribed order which is often unfavourable.
73 DEEMED DOMICILE (CONT) Legislation has been revised: When someone becomes deemed domiciled, he is now allowed to offset all his losses against gains without having to distinguish between UK and foreign disposals. If he loses his deemed domicile but later returns to UK, he can once again access remittance basis and make capital loss election afresh.
74 DEEMED DOMICILE (CONT) No special IHT provisions for long-term residents. Rebasing relief individuals who become deemed domiciled as long-term residents as at 6 April 2017 are able to rebase their foreign assets to MV on 5 April Conditions for individual s rebasing relief: He must not be FDR.
75 DEEMED DOMICILE (CONT) He must not be domiciled in UK under general law during tax year when asset is disposed of. He must have held asset on 5 April 2017, with disposal taking place at later date. Asset must have foreign situs throughout period from 16 March 2016 (or date of acquisition, if later) to 5 April 2017.
76 DEEMED DOMICILE (CONT) Other stipulations: He must have been resident in UK for at least 15 out of last 20 tax years up to 2016/17 and must remain UK-resident in 2017/18. He must have paid remittance basis charge at least once prior to 2017/18 (this means that minors can never benefit from rebasing relief).
77 DEEMED DOMICILE (CONT) Rebasing relief is only available for assets held directly by individuals no rebasing for assets held by trusts or companies. If asset is to be rebased, individual must make election which, once made, cannot be revoked. This election operates on asset-byasset basis.
78 CLEANSING OF MIXED FUNDS For period of 2 years starting on 6 April 2017, non-uk domiciliaries who have claimed remittance basis can rearrange their bank accounts and separate different component parts into: clean capital; foreign income; and foreign gains.
79 CLEANSING OF MIXED FUNDS (CONT) They can then make tax-free remittance to UK from their clean capital. Existing mixed fund rules are being disapplied for time being. Requirements are: transfer of money made during 2017/18 or 2018/19; transfer is made from mixed fund;
80 CLEANSING OF MIXED FUNDS (CONT) transfer is made into different receiving account; transfer is appropriately nominated by non-uk domiciliary; no other transfer has been nominated from that mixed fund into receiving account; and transfer is made by qualifying individual.
81 CLEANSING OF MIXED FUNDS (CONT) Qualifying individual means individual who has been taxed on remittance basis for any tax year prior to 2017/18 and who is not FDR. Relief does not apply to non-monetary assets. But non-monetary asset can be sold during 2-year transitional window, with sale proceeds then being separated out.
82 ATED IN 2017 ATED is annual tax payable by companies and certain other NNPs owning UK residential property worth more than 500,000. Tax charges for financial year 2017 (ie. 12 months to 31 March 2018). 5-year revaluation on 1 April ATED reliefs and exemptions (eg. for property let out commercially).
83 ATED IN 2017 (CONT) Reliefs should be claimed on ATED Relief Declaration Return. Do not overlook recent reductions in valuation thresholds.
84 NEW 100% FYA For expenditure incurred on or after 23 November 2016, cost of new electric vehicle charging point qualifies for 100% FYA. This form of tax relief will run until 31 March (or 5 April) Intended to make installation of electric charge-points more common feature on high streets.
85 NEW 100% FYA (CONT) Detailed guidance to be published by HMRC later this year.
86 CORPORATION TAX LOSS RELIEF Reform of corporation tax rules for carryforward of trading losses w.e.f. 1 April Losses covered include: trading losses; management expenses; non-trading loan relationship deficits; UK property losses; and
87 CORPORATION TAX LOSS RELIEF (CONT) non-trading losses on intangibles. Consultation document published in May Government has 2 aims in modernising tax system these are to: widen scope of carry-forward rules; and restrict profits against which such losses can be set.
88 CORPORATION TAX LOSS RELIEF (CONT) Government s plans are twofold: when corporate losses arise on or after 1 April 2017, they can be carried forward and set against other (ie. nontrading) profits or surrendered; and w.e.f. 1 April 2017, amount of profits which can be relieved by losses carried forward will be limited to 50%, subject to annual allowance of 5,000,000.
89 CORPORATION TAX LOSS RELIEF (CONT) This allowance will apply per company or per group (as case may be). Capital losses are still to be ring-fenced (ie. they can only be relieved against chargeable gains). Comprehensive pro forma for company s loss position provided by F(No2)B Other points to mention include:
90 CORPORATION TAX LOSS RELIEF (CONT) where company s profits include both trading and non-trading sources, inyear losses and group relief no longer have to be split on pro rata basis; group/company has absolute discretion as to allocation of 5,000,000 limit; meaning of group for this purpose is based on group relief definition; and
91 CORPORATION TAX LOSS RELIEF (CONT) pre-1 April 2017 losses which are carried forward will still be subject to existing streaming rules, ie. they can only be carried forward against profits of same trade. See Illustration. New terminal loss relief regime on cessation of trade.
92 CORPORATION TAX LOSS RELIEF (CONT) Same trade restriction for companies where trade, which once flourished, has now become small or negligible. Anti-avoidance where there is: change of ownership; and major change in nature or conduct of trade within 3-year period.
93 CORPORATION TAX LOSS RELIEF (CONT) 3-year period has been widened to 5 years. On change of ownership, any preacquisition losses in acquired company cannot be group relieved for 5 years.
94 CORPORATE INTEREST TAX RELIEF Consultation paper published on 22 October Aimed at countering aggressive tax planning, mainly by large companies. Idea for restriction of debt relief inspired by OECD s BEPS initiative. Hitherto, UK only had limited protection: transfer pricing rules; and
95 CORPORATE INTEREST TAX RELIEF (CONT) large company worldwide debt cap. In addition, there are several TAARs to supplement transfer pricing legislation. Some countries, eg. Australia, Germany and Japan, have general provision which limits interest relief. W.e.f. 1 April 2017, corporate group s net interest relief is to be capped at fixed percentage of taxable UK profits.
96 CORPORATE INTEREST TAX RELIEF (CONT) Cap has been set at 30% of EBITDA, subject to de minimis threshold of 2,000,000. Alternative group ratio rule which may produce higher percentage this is found by expressing net group interest expense as percentage of group EBITDA. Modified debt cap. Unrelieved interest to be carried forward.
97 SSE REFORM SSE introduced in FA 2002 detailed rules found in Sch 7AC TCGA Capital gains exemption for companies selling trading subsidiaries and corporate investments where they hold stake of at least 10% of O.S.C. (+ other economic rights). No distinction between sales of shares in UK-resident and overseas companies.
98 SSE REFORM (CONT) Main conditions for SSE are: Investing company must be sole trading company or member of trading group through relevant 12-month period. Immediately after disposal, this must still apply. Relevant 12-month period can start no more than 2 years before disposal date.
99 SSE REFORM (CONT) Investee company must be trading company or holding company of trading sub-group throughout relevant 12- month period. Immediately after disposal, investee company must still be trading company or member of trading group. Consultation on reform of SSE rules launched by Government in 2016.
100 SSE REFORM (CONT) Perceived problem area was that both companies had to be undertaking trading activities property investment business does not qualify. Changes taking effect for disposals made on or after 1 April 2017 are: removal of investing company trading condition;
101 SSE REFORM (CONT) extension of start of relevant 12-month period from 2 to 6 years before disposal; removal of post-disposal investee company trading condition (but only for third party sales); and broader exemption for companies owned by institutional investors.
102 TRANSACTIONS IN UK LAND Ss76 82 FA 2016 brought non-uk resident developers of UK property fully into UK tax on any profits arising from dealing in or developing land in UK. These rules excluded profits from transactions entered into before relevant commencement date (5 July 2016). Government assumed that such contracts followed standard pattern.
103 TRANSACTIONS IN UK LAND (CONT) But it became apparent that some contracts would have been entered into several months (or even years) before transfer of property and recognition of profit. It was never Government s intention to allow these profits to escape tax charge. FA 2016 commencement date has therefore been changed.
104 TRANSACTIONS IN UK LAND (CONT) All such profits recognised in accounts on or after 8 March 2017 under GAAP will be taxed, regardless of date when contract was signed.
105 ENABLERS New penalty regime for enablers of defeated tax avoidance schemes, ie. anyone who enabled use of abusive tax arrangements. To be enabler, person must have designed, managed or marketed failed tax planning arrangements. Person is also caught if his involvement was essential to hoped-for success.
106 ENABLERS (CONT) And someone who provided financial product which allowed taxpayer to participate in arrangement is also classified as enabler. Definition of abusive tax planning uses familiar double reasonableness test. Arrangements are defeated once all avenues for appealing against HMRC s stance have disappeared.
107 ENABLERS (CONT) Penalty = fee received by enabler for his involvement with scheme. HMRC must, before issuing penalty notice, take into account opinion of 7-man GAAR Advisory Panel. Penalty notices are appealable. Regime will apply to arrangements entered into on or after date of Royal Assent.
108 ENABLERS (CONT) HMRC have confirmed that advisers acting within spirit of updated Professional Conduct in Relation to Taxation are unlikely to be affected by new code.
109 2016/17 TAX RETURNS For many years, PA has been offset in following order: non-savings income; then interest; and finally dividends. This normally produced most tax-efficient end result see S25(2) ITA No longer position for 2016/17 onwards.
110 2016/17 TAX RETURNS (CONT) Caused by introduction in FA 2016 of: personal savings allowance; and dividend tax allowance. Individual s personal savings allowance can be 1,000, 500 or zero (depending on marginal rate of tax). But dividend tax allowance is 5,000 for everyone.
111 2016/17 TAX RETURNS (CONT) Where individual s total income includes interest received, it is important to try and maximise benefit of: 0% starting rate for savings income; and personal savings allowance. 0% starting rate is only in point for those whose non-savings income does not exceed PA plus maximum of 5,000.
112 2016/17 TAX RETURNS (CONT) Problem with HMRC s online filing parameters for 2 groups of taxpayer: those with income (including interest) of > 32,000 where non-savings income is between 11,000 and 16,000; and those with non-dividend income of between 27,000 to 32,000 where total income (including dividends) is > 145,000.
113 2016/17 TAX RETURNS (CONT) In first case, software will not apply 0% starting rate to income falling within starting rate band, ie. there will be charge of 20% (rather than 0%). In second case, software will treat dividend higher rate band as reduced by full amount of dividend tax allowance, even though there may have been spare capacity in basic rate band, ie. more dividends will be pushed into 38.1% band.
114 2016/17 TAX RETURNS (CONT) Affected taxpayers should submit paper tax returns for 2016/17. Normally, this must be done by 31 October However, HMRC confirm that they will have until 31 January 2018 there is reasonable excuse for late filing. Correction difficulty if return is inadvertently filed online.
115 2016/17 TAX RETURNS (CONT) HMRC promise that this will be sorted for 2017/18 tax returns. Not fault of tax software providers their software must follow HMRC s parameters. If it does not, none of their online tax returns will be accepted. They had no choice but to code their products to give incorrect outcome.
Reform of the Non-Dom Regime - December 2016
19 December 2016 Note: The government finalised the reform of the non-dom regime, and this was part of the second Finance Act of 2017 which gained Royal Assent on 16 November 2017 - please see our technical
More informationFINANCE BILL /FINANCE ACT UPDATE
FINANCE BILL /FINANCE ACT UPDATE Robert Jamieson MA FCA CTA (Fellow) TEP Wayfarers Barn, Steventon, Basingstoke, Hampshire RG25 3AY Tel: 01256 782828 Fax: 01256 782076 Mob: 07801 932500 E-mail: robertianjamieson@hotmail.com
More informationSummary of UK tax changes coming into force from 6 April 2017
Summary of UK tax changes coming into force from 6 April 2017 In the Summer Budget 2015 it was announced that there would be significant changes to the way those who were not domiciled in the UK and living
More informationMost of our clients are individuals or small and medium-sized businesses (or both). The headlines affecting them are as follows:
H M Revenue & Customs have now published draft provisions for inclusion in Finance Bill 2017, which should be enacted next summer. There are also some announcements affecting possible tax law changes after
More informationCHANGES FOR NON-UK DOMICILES: DEEMED DOMICILE FROM 2017
Harriet Brown Old Square Tax Chambers 15 Old Square, Lincoln s Inn, London WC2A 3UE T: (020)7242 2744 F: (020)7831 8095 harrietbrown@15oldsquare.co.uk CHANGES FOR NON-UK DOMICILES: DEEMED DOMICILE FROM
More informationDraft Finance (No.2) Bill 2017
13 July 2017 Draft Finance (No. 2) Bill 2017 Draft Finance (No.2) Bill 2017 The Government has announced today that the Finance (No.2) Bill 2017, which brings back measures deferred from Finance Act 2017,
More informationAPRIL 2017 UK TAX CHANGES: BE PREPARED
APRIL 2017 UK TAX CHANGES: BE PREPARED MARCH 2017 The UK Government will radically revise the UK tax regime for long-term resident but non-domiciled individuals from 6 April 2017. These plans have been
More informationNon-domicile taxation Finance Bill 2017
Non-domicile taxation Finance Bill 2017 1 Non-domicile taxation: background Major changes to taxation of UK resident nondoms in 2008 Further changes in 2009, 2010, 2012, 2013, 2014 and 2015 Major reforms
More informationThe personal allowance will increase to 11,000 in April 2016 with a further increase to 11,500 in April 2017.
The Budget in brief Date posted: 18.3.16 Income tax The personal allowance will increase to 11,000 in April 2016 with a further increase to 11,500 in April 2017. The higher rate threshold will increase
More informationCountdown to 6 April 2017 for non-uk domiciliaries
PRIVATE CLIENT Countdown to 6 April 2017 for non-uk domiciliaries December 2016 In July 2015, the Government announced significant changes to the taxation of resident non-uk domiciled individuals and their
More information2016 AUTUMN STATEMENT
2016 AUTUMN STATEMENT Highlights l Salary sacrifice schemes The tax and NIC advantages of most salary sacrifice schemes will be removed from April 2017 as previously proposed, but there will be some transitional
More informationTAX DATA 2018/ BUDGET EDITION 22 NOVEMBER CHANCERY LANE LONDON WC2A 1 LS
TAX DATA 2018/2019 BUDGET EDITION 22 NOVEMBER 2017 22 CHANCERY LANE LONDON WC2A 1 LS TELEPHONE 020 7 680 8100 E-MAIL dw@dixonwilson.co.uk 19 AVENUE DE L OPERA 75001 PARIS TELEPHONE + 33 1 47 03 12 9 0
More informationDeemed UK Domicile Changes Action Required Now!
BRIEFING NOTE February 2018 Deemed UK Domicile Changes Action Required Now! The principal changes that are effective from 6 April 2017 are as follows: Anyone born in the UK with a UK domicile of origin
More informationUK SUMMER BUDGET July 2015
UK SUMMER BUDGET 2015 8 July 2015 The Chancellor, George Osborne released his first all-conservative Government Budget since 1997 on Wednesday, 8 July 2015. The Chancellor described this Budget as focusing
More informationHMT: Reforms to the taxation of nondomiciles. The Law Society's response November The Law Society. All rights reserved.
HMT: Reforms to the taxation of nondomiciles The Law Society's response November 2015 2015 The Law Society. All rights reserved. 1. The Law Society is the professional body for solicitors in England and
More informationTAX CHANGES FOR NON-UK DOMICILIARIES DRAFT FINANCE BILL 2017 DECEMBER 2016 UPDATE
TAX CHANGES FOR NON-UK DOMICILIARIES DRAFT FINANCE BILL 2017 DECEMBER 2016 UPDATE 2 TAX CHANGES FOR NON-UK DOMICILIARIES DECEMBER 2016 UPDATE CONTENTS Introduction 3 Deemed UK Domicile 4 Opportunity To
More informationUK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018
UK PROPERTY TAXES COMMERCIAL AND RESIDENTIAL UPDATE JUNE 2018 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with
More informationPROJECT TITLE UK PROPERTY TAXES UPDATE
PROJECT TITLE UK PROPERTY TAXES UPDATE 2017 TIMELINE OF TAX CHANGES The last few years have seen a transformation in the landscape for the taxation of property ownership in the UK with further changes
More informationRESIDENTIAL PROPERTY AND DIVIDEND CHANGES. Robert Jamieson MA FCA CTA (Fellow) TEP 22 September 2016
RESIDENTIAL PROPERTY AND DIVIDEND CHANGES Robert Jamieson MA FCA CTA (Fellow) TEP 22 September 2016 BUY-TO-LET TAX CHANGES At present, full income tax relief is normally available for interest on loan
More informationThe Law Society's response. January The Law Society. All rights reserved. PERSONAL/IAD-EU /8
HMRC and HM Treasury: Clause 42 and Schedule 13 of the Draft Finance Bill 2017: Inheritance tax on overseas property with value attributable to UK residential property The Law Society's response January
More informationYear end tax planning guide 2017/2018
Year end tax planning guide 2017/2018 At Handelsbanken Wealth Management we make every effort to advise clients on sensible and appropriate ways to reduce or defer their tax burden in a straight forward
More informationThe new era non-residents and UK residential property
The new era non-residents and UK residential property Emma Chamberlain Pump Court Tax Chambers 16 Bedford Row London WC1R 4EF echamberlain@pumptax.com Tel 0207 414 8080 October 2015 STEP Overview A mess
More informationTax Planning for Individuals
Tax Planning for Individuals 2018 03333 219 000 advice@bishopfleming.co.uk www.bishopfleming.co.uk Tax Planning for Individuals 2018 Key Updates Income tax 150k 45% 100k- 123k 60% 11,500 Personal Allowance
More informationPrivate Client Briefing
chartered accountants & tax advisers Private Client Briefing Spring 2018 Articles in this edition Annual planning opportunites Residential landlords restrictions on mortgage interest Making tax digital
More informationCapital Gains Tax Tackling Property Business Incorporations
Capital Gains Tax Tackling Property Business Incorporations Peter Rayney * FCA CTA (Fellow) TEP, Peter Rayney Tax Consulting Ltd Capital gains tax; Incorporation; Incorporation relief; Inheritance tax;
More informationBRIEFING FOREIGN DOMICILIARIES WHERE ARE WE NOW? Introduction
FOREIGN DOMICILIARIES WHERE ARE WE NOW? Introduction Our October 2017 Briefing summarised the position as it was at 11 October 2017 at which time: the September Finance Bill was progressing through Parliament;
More informationFinance Bill Finance Bill Bill, consultations and guidance published on 20 March 2017
20 March 2017 Finance Bill 2017 Finance Bill 2017 Bill, consultations and guidance published on 20 March 2017 Finance Bill 2017, published as Finance (No.2) Bill 2016-17, could be considered to be the
More informationTAX GUIDE YEAR-END 2016/17.
YEAR-END TAX GUIDE 2016/17 023 8046 1200 www.hwb-accountants.com admin@hwb-accountants.com HWB is a trading name of Hopper Williams and Bell Limited. Registered to carry on audit work in the UK and regulated
More informationMonthly Tax Webinar. December Agenda. Martyn Ingles
Monthly Tax Webinar December 2015 Martyn Ingles Agenda Autumn Statement 2015 Draft Finance Bill 2016 Clauses Recent Tax Cases and other developments Tax planning when is expenditure incurred for capital
More informationIn the first of a two-part series, Emma Chamberlain considers the capital gains tax issues arising on divorce
Capital split 1 June 2015 In the first of a two-part series, Emma Chamberlain considers the capital gains tax issues arising on divorce What is the issue? Are payments by foreign domiciliaries to civil
More informationForeign domiciliaries and trusts. IHT changes to residential property. Speaker: Giles Clarke. A. Deemed Domicile
Foreign domiciliaries and trusts IHT changes to residential property Speaker: Giles Clarke A. Deemed Domicile Introduction Until 5 April 2017, a non UK domiciliary could only be deemed to be UK domiciled
More informationAnnual residential property tax and capital gains tax rules for non-natural persons
Annual residential property tax and capital gains tax rules for non-natural persons STEP is the worldwide professional association for practitioners dealing with family inheritance and succession planning.
More informationRebasing and the changes to the CGT foreign capital losses election - professional bodies Q&As
TAXguide 06/18 Rebasing and the changes to the CGT foreign capital losses election - professional bodies Q&As Version 1 (without HMRC comments see foreword - published 27 March 2018 CONTENTS Foreword QUESTIONS
More informationWelcome. UK Tax Update Jason Laity. 7 December, 2016
Welcome UK Tax Update Jason Laity 7 December, 2016 Agenda 8:30-8:35 Introduction Jason Laity 8:35-8:55 UK residential property Jason Laity 8:55-9:25 Long term UK residents, including rebasing, mixed funds,
More informationBARNES ROFFE LLP TAX STRATEGIES FOR PROPERTY INVESTORS
BARNES ROFFE LLP TAX STRATEGIES FOR PROPERTY INVESTORS Keith Mason / Paul Hughes 27 th September 2018 Seminar Coverage Residential Buying Renting Selling Keeping Changing Commercial Buying Renting Selling
More informationUK issues 2015 Autumn Statement
30 November 2015 Global Tax Alert UK issues 2015 Autumn Statement EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More information15 Old Square, Lincoln s Inn London WC2A 3UE. Amanda Hardy QC
15 Old Square, Lincoln s Inn London WC2A 3UE taxchambers@15oldsquare.co.uk www.taxchambers.com Amanda Hardy QC Update on draft clauses HMRC Stakeholder Meetings The Legislation excluded property The two
More informationCONTENTS CAPITAL GAINS TAX SIMPLIFICATION CAPITAL GAINS TAX SIMPLIFICATION. Introduction DOMICILE AND RESIDENCE
CONTENTS CAPITAL GAINS TAX SIMPLIFICATION DOMICILE AND RESIDENCE DEEDS OF VARIATION AFTER 8 OCTOBER 2007 CORPORATE INVESTMENT IN LIFE ASSURANCE BONDS CAPITAL GAINS TAX SIMPLIFICATION Draft legislation
More informationA CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 14 September 2017
A CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 14 September 2017 COMPANY DISTRIBUTIONS Following liquidation, shareholder will receive capital distribution
More informationA CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 12/18 October 2017
A CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 12/18 October 2017 COMPANY DISTRIBUTIONS Following liquidation, shareholder will receive capital distribution
More informationA CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 29 September 2017
A CAPITAL GAINS TAX UPDATE (TO INCLUDE ENTREPRENEURS RELIEF) Robert Jamieson MA FCA CTA (Fellow) TEP 29 September 2017 COMPANY DISTRIBUTIONS Following liquidation, shareholder will receive capital distribution
More informationof 40, with a maximum contribution of 4,000 a year and a 25% bonus. The standard ISA investment limit will rise to 20,000 at the same time.
Budget highlights l The launch of a new Lifetime ISA from April 2017 for adults under the age of 40, with a maximum contribution of 4,000 a year and a 25% bonus. The standard ISA investment limit will
More informationUpdate. Changes to the taxation of non UK domiciliaries first thoughts. Private client tax. Deemed domicile
Update Private client tax Changes to the taxation of non UK domiciliaries first thoughts The Government announced its intention to change the tax treatment of non-uk domiciliaries ( non-doms ) in the Summer
More informationThe first major economic statement since the EU referendum focused on measures to "prepare our economy to be resilient as we exit the EU".
Autumn Statement 2016 Introduction The first major economic statement since the EU referendum focused on measures to "prepare our economy to be resilient as we exit the EU". Unsurprisingly, the Office
More informationThe taxation of UK residential property: changes and proposals
The taxation of UK residential property: changes and proposals Surprise measures to increase the scope of certain taxes on higher value residential property acquired by and/or held through corporate envelopes
More informationREFORM OF THE TAXATION INDIVIDUALS CONSULTATION DOCUMENT OF NON DOMICILED OF 17 JUNE SPEAKER: GILES CLARKE 7 September 2011
REFORM OF THE TAXATION OF NON DOMICILED INDIVIDUALS CONSULTATION DOCUMENT OF 17 JUNE 2011 SPEAKER: GILES CLARKE 7 September 2011!"#$%&%'%()&*+(%&"+,&-%%.&/+0%.&/1&%.,2(%&/"%&+**2(+*)&13&/"%,%&.1/%,&+.4&/"%&+**156+.)#.7&/+$08&.1&(%,61.,#-#$#/)&31(&$1,,&1**+,#1.%4&
More informationAIM. A guide to AIM tax benefits
AIM A guide to AIM tax benefits A guide to AIM UK tax benefits AIM AIM is London Stock Exchange s market for smaller, growing companies from the UK and across the globe. AIM provides an ideal environment
More informationA) Deemed domicile income and CGT (clauses and schedules 8-9)
Briefing Note from the Chartered Institute of Taxation for Finance Bill 2017-19 Domicile, overseas property etc (clauses 29-33 and schedules 8-10) NB. This briefing note is separated into two parts the
More informationFinance (No. 2) Bill 2017 Explanatory Notes
Finance (No. 2) Bill 2017 Explanatory Notes 20 March 2017 Explanatory notes Introduction 1. These explanatory notes relate to the Finance (No. 2) Bill 2017 as introduced into Parliament on 20 March 2017.
More informationUK tax year end planning. Optimise your affairs before the end of the 2017/18 tax year and prepare for the year ahead
UK tax year end planning Optimise your affairs before the end of the 2017/18 tax year and prepare for the year ahead Page 1 Contents UK tax planning: 2017/18 tax year end... 2 Year end tax planning checklist...
More informationForeign Tax Alert Stay informed of new developments
Singapore Tax 8 December 2014 Foreign Tax Alert Stay informed of new developments Capital Gains Tax and UK residential property On 27 November 2014 the UK government published its response to the consultation
More informationYear-end tax planning checklist. TWP: Chartered Accountants & Tax Advisers
Year-end tax planning checklist TWP: Chartered Accountants & Tax Advisers With the current tax year ending on 5 April 2017, it is important to utilise all the tax reliefs and allowances available before
More informationThe non-dom newsletter
December 2016 Tax Services The non-dom newsletter Twelfth edition - Draft Finance Bill Special 8 December 2016 Introduction Welcome to the Draft Finance Bill Special edition of the non-dom newsletter.
More informationRadical reform of pensions, effectively introducing flexible drawdown for all defined contribution schemes.
Budget highlights Radical reform of pensions, effectively introducing flexible drawdown for all defined contribution schemes. Major relaxations to the rules for turning small pension pots into cash lump
More informationPersonal tax and trust planning
Personal tax and trust planning AF1: 2017 18 edition 2: 14 February 2018 Please note the following update to your copy of the AF1 2017 18 case study workbook: Pensions advice The plan to introduce a new
More informationQUARTER LEGISLATIVE UPDATE
QUARTER 1 2017 LEGISLATIVE UPDATE Legislative update GUIDING YOU THROUGH THE LATEST CHANGES Our legislative update helps you make the most of changes to pensions law and regulation. Guiding you through
More informationA little boost. What is the issue? What does it mean to me? What can I take away? 1 March 2018
A little boost 1 March 2018 Lynne Poyser provides practical guidance on claiming the 1000 allowances for trading and property What is the issue? The 1,000 allowances for property and trading income came
More informationThe non-dom newsletter
September 2015 Tax Services The non-dom newsletter Introduction Welcome to the first edition of our Non-Dom Newsletter. This newsletter has a single focus: to keep you abreast and advised of the changing
More informationYEAR END TAX PLANNING
2015/16 YEAR END TAX PLANNING 2015/16 Introduction Income Tax Tax-efficient Investments Social Investment Tax Relief Residential Landlords Restrictions on Mortgage Interest Dividend Tax Credit Pensions
More informationBUDGET HIGHLIGHTS. n A reduction in the dividend allowance from the current 5,000 to 2,000 from 2018/19.
BUDGET HIGHLIGHTS n A reduction in the dividend allowance from the current 5,000 to 2,000 from 2018/19. n A 1% increase in the main Class 4 NIC rate to 10% for 2018/19 and a further 1% addition to 11%
More informationCompany distributions
Company distributions Response to the HMRC consultation document of 9 December 2015 3 February 2016 1. Introduction 2 1.1 Overarching objectives 2 2. Executive summary 2 3. General comments 2 4. Responses
More informationCombatting Tax Avoidance. John Barnett CTA (Fellow) TEP Partner, Burges Salmon LLP
Combatting Tax Avoidance John Barnett CTA (Fellow) TEP Partner, Burges Salmon LLP The War on Tax Avoidance Disclosure of Tax Avoidance Schemes (DOTAS) update Accelerated Payment Notices Information Powers
More informationRESIDENTIAL INVESTORS & LANDLORDS TAX INFORMATION
RESIDENTIAL INVESTORS & LANDLORDS TAX INFORMATION The following notes are intended to provide a useful background for investors buying and letting individual residential properties. Independent advice,
More informationBudget. Summary spring edition 2013
Budget Summary spring edition 2013 Institute of Financial Accountants Burford House, 44 London Road, Sevenoaks TN13 1AS T: +44 (0)1732 458080 F: +44(0)1732 455848 E: mail@ifa.org.uk ifa.org.uk Registered
More informationUK Tax Update: It s not all about Brexit!
August 2016 UK Tax Update: It s not all about Brexit! There has rightly been a great deal of attention paid to the UK s decision to leave the EU and what that may mean from a business (including tax) perspective.
More informationBudget & Finance Bill Update Mike Hayes & Geraint Lewis
Budget & Finance Bill Update - 2013 Mike Hayes & Geraint Lewis Main topics Personal tax allowances & rates Inheritance tax New residence rules Mansion tax Anti-avoidance VAT & other indirect taxes Business
More informationYear end tax planning 2017/18
BOND Chartered Accountants KEY GUIDE Year end tax planning 2017/18 Income tax saving for couples If you re in a couple, you might be able to save tax by switching income from one spouse or partner to the
More informationDISCUSSION DRAFT POSSIBLE TREATMENT OF OFFSHORE SETTLEMENTS FOR NON- DOMICILIARIES AFTER 6 APRIL 2017
DISCUSSION DRAFT POSSIBLE TREATMENT OF OFFSHORE SETTLEMENTS FOR NON- DOMICILIARIES AFTER 6 APRIL 2017 Background This paper has been prepared by representatives of the CIOT, Law Society, STEP and ICAEW
More informationCunning disguise. Then there were the HMRC 'spotlights', in particular Spotlight 5, and Revenue & Customs briefs 61/09 and 18/11.
TAXATION Published on Taxation (http://www.taxation.co.uk/taxation) Cunning disguise Written by Nigel Holmes and Graham Poles HMRC do not like employee benefit trusts. Nigel Holmes and Graham Poles examine
More informationTax Facts BRINGING TAX INTO FOCUS RATES AND ALLOWANCES GUIDE 2018 /
Tax Facts RATES AND ALLOWANCES GUIDE 2018 / 2019 BRINGING TAX INTO FOCUS www.hazlewoods.co.uk CONTENTS PERSONAL TAX Page Income tax rates and allowances 1 Timetable for self-assessment 3 Pensions 3 Capital
More informationTAX PLANNING CHECKLIST FOR YEAR END
TAX PLANNING CHECKLIST FOR YEAR END 2019 INTRODUCTION As the end of another tax year approaches, now is a good time to consider your financial position and check whether you have taken full advantage of
More informationSTEP comments on Reforms to the taxation of non-domiciles draft legislation issued on 5 December 2016
STEP comments on Reforms to the taxation of non-domiciles draft legislation issued on 5 December 2016 Inheritance Tax on UK Residential Property New Schedule A1 IHTA 1984 STEP is the worldwide professional
More informationNon Domiciled Individuals
Non Domiciled Individuals www.baldwinsaccountants.co.uk I t: 0845 894 8966 I e: info@baldwinandco.co.uk This factsheet sets out the rules which deal with the taxation in the UK of income arising outside
More informationUK issues draft Finance Bill 2014 clauses for consultation
11 December 2013 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More information2015 Autumn Statement
David Grey & Co. CHARTERED ACCOUNTANTS 2015 Autumn Statement 177 Temple Chambers Temple Avenue London EC4Y 0DB T: 020 7353 3563 F: 020 7353 3564 E: post@davidgreyco.com Highlights In the first combined
More informationPrivate Client Services
Private Client Services Residential property Charges for non-natural persons March 2013 Residential property: charges for non-natural persons The 2012 Chancellor s Budget contained a number of announcements
More informationtaxcalc.com
By By 1 taxcalc.com 0845 5190 883 THE BUDGET AND FINANCE BILL 2015 Key issues for the general practitioner CONTENTS To find out more about TaxCalc s range of products and services please visit taxcalc.com
More informationYear end tax strategies 2018
PKF Littlejohn LLP Helping you make the most of tax-saving opportunities Year end tax www.pkf-littlejohn.com Key points CAPITAL GAINS EXEMPTION 11,300 for 2017/18 INTEREST Up to 1,000 tax free per year
More informationUK releases draft legislation on rules restricting deductibility of corporate interest expense
World Tax Advisor Connecting you globally. 16 December 2016 UK releases draft legislation on rules restricting deductibility of corporate interest expense On 5 December 2016, following extensive consultation,
More informationDavid Grey & Co Spring Budget. 177 Temple Chambers Temple Avenue London EC4Y 0DB T: F: E:
David Grey & Co. CHARTERED ACCOUNTANTS 2017 Spring Budget 177 Temple Chambers Temple Avenue London EC4Y 0DB T: 020 7353 3563 F: 020 7353 3564 E: post@davidgreyco.com BUDGET HIGHLIGHTS n A reduction in
More informationUK year end tax planning: the essential guide
UK year end tax planning: the essential guide The end of the 2016-17 tax year is rapidly approaching so take some time to review some of the matters that may be relevant to you and your business it could
More informationBudget Summary - Spring 2017
Budget Summary - Spring 2017 Spring Budget 8 March 2017 BUDGET HIGHLIGHTS A reduction in the dividend allowance from the current 5,000 to 2,000 from 2018/19. A 1% increase in the main Class 4 NIC rate
More informationBudget Introduction. Budget highlights
The Spring Budget 2016 Spring Budget 2016 Budget highlights Introduction Personal taxation Pensions, savings and investments Capital taxes Business tax Value added tax Anti-avoidance measures National
More informationTAX RATES. for 2015/2016 & ALLOWANCES. simplifying the everyday. for freelancers & contractors
TAX RATES & ALLOWANCES for 2015/2016 for freelancers & contractors simplifying the everyday. Taxes rates & allowances guide Contents Corporation tax 4 Value Added Tax 4 Capital allowances 5 Patent Box
More informationCharges on income for corporation tax purposes
Charges on income for corporation tax purposes Part 8 /Chapter 2 This document should be read in conjunction with section 247 of the Taxes Consolidation Act Document last updated/reviewed on June 2017
More informationInternational Tax United Kingdom Highlights 2019
International Tax United Kingdom Highlights 2019 Updated January 2019 Recent developments: For the latest tax developments relating to the UK, see Deloitte tax@hand. Investment basics: Currency Pound Sterling
More informationAUTUMN BUDGET November The Budget. chartered accountants & tax advisers
chartered accountants & tax advisers AUTUMN BUDGET 2017 November 2017 - The Budget The Chancellor Philip Hammond delivered his second Budget earlier this afternoon, in uncertain, pre-brexit times. Delayed
More informationFor Adviser use only Not approved for use with clients. Estate Planning
For Adviser use only Not approved for use with clients Adviser Guide Estate Planning Contents Inheritance tax: Facts and figures 4 Summary of IHT rules 5 Choosing a trust 8 Prudence Inheritance Bond (Discounted
More informationTAX DISPUTE RESOLUTION THE REQUIREMENT TO CORRECT A NEW COMPLIANCE OBLIGATION FOR UK TAXPAYERS
TAX DISPUTE RESOLUTION THE REQUIREMENT TO CORRECT A NEW COMPLIANCE OBLIGATION FOR UK TAXPAYERS New legislation that requires taxpayers with outstanding tax liabilities relating to offshore interests, where
More informationGuidelines for buying and selling a business or company
Guidelines for buying and selling a business or company Introduction This section covers the main tax issues that arise when buying or selling a business owned by a sole trader, a partnership or a company.
More informationTax deductibility of corporate interest expense
Tax Services 13 May 2016 Tax deductibility of corporate interest expense Further consultation Consultation on detailed policy design and implementation On 12 May 2016, HM Treasury and HMRC released a further
More informationthe second budget report 2015
iness ax savings and personal pensions VAT what will he say? National Insurance Contributions the second budget report 2015 A summary of the Chancellor s Statement www.hwca.com The Second Budget 2015 George
More informationBUDGET HIGHLIGHTS. A reduction in the dividend allowance from the current 5,000 to 2,000 from 2018/19.
SPRING BUDGET 2017 BUDGET HIGHLIGHTS A reduction in the dividend allowance from the current 5,000 to 2,000 from 2018/19. A new 25% tax charge on transfers to qualifying recognised overseas pension schemes
More informationINHERITANCE TAX RELIEFS: EXPENSES AND LIABILITIES
INHERITANCE TAX RELIEFS: EXPENSES AND LIABILITIES Tolley Guidance October 2013 Disclaimer Tolley Guidance takes every care when preparing this material. However, no responsibility can be accepted for any
More informationNon-resident capital gains taxation on direct and indirect sales of UK property
July 2018 Draft Finance Bill clauses Non-resident capital gains taxation on direct and indirect sales of UK property Summary of proposals Gains on disposals of all UK property and certain UK property rich
More informationTAX DISPUTE RESOLUTION. THE REQUIREMENT TO CORRECT A new compliance obligation for UK taxpayers
TAX DISPUTE RESOLUTION THE REQUIREMENT TO CORRECT A new compliance obligation for UK taxpayers 2 BDO LLP REQUIREMENT TO CORRECT New legislation that requires taxpayers with outstanding tax liabilities
More informationThe Chartered Tax Adviser Examination
The Chartered Tax Adviser Examination November 2015 Taxation of Individuals Advisory Paper Suggested Solutions Question 1 1) A Tax Manager Big Firm London AB12 3CD 31 May 2015 Mr P Johnson Blocks Group
More informationAutumn Budget 2017: The Budget, in full
www.ukbudget.com 22 November 2017 Autumn Budget 2017: The Budget, in full Contents Introduction 1 Tackling tax avoidance, evasion and non-compliance 2 Real estate 2.1 UK real estate 2.2 CGT payment deadline
More informationKEY GUIDE. Living abroad the main tax rules
KEY GUIDE Living abroad the main tax rules Planning to leave the UK While the thought of going abroad to work or retire may be exciting, the months before departure may be stressful. Finding somewhere
More informationCHARTERED CERTIFIED ACCOUNTANTS 2017 SPRING BUDGET
CHARTERED CERTIFIED ACCOUNTANTS 2017 SPRING BUDGET BUDGET SUMMARY 8 MARCH 2017 1 BUDGET 8 MARCH 2017 This Summary covers the key tax changes announced in the Chancellor s speech and includes tables of
More information