Enterprise in the spotlight

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1 In this issue: ixbrl: Here to stay Protect yourself Tax and non-domiciles Good cheer for charities The Employer s Charter Case study Claim the opportunity Private client services Life assurance and IHT planning Planning for school and university fees Buy-to-let finance market update Maximise your pension contributions Communiqué Enterprise in the spotlight George Osborne s second Budget was, he promised, one that would encourage greater enterprise and open the UK to business. My ambition, he told the House of Commons on 23 March, is to make Britain the best place in Europe to start and grow a business. Communiqué Issue

2 Cover story Business news But what did that mean in practice? The headline announcement was a 2% reduction in corporation tax, followed by a 1% cut in subsequent years to bring the rate down to 23%. The introduction of a fuel stabiliser was also welcome news for businesses that have seen their transport costs soar over recent months. The Chancellor made several announcements intended to reduce the burden of red tape on Britain s companies, including a promise to act on the recommendations of the Office of Tax Simplification (involving the abolition of 43 different tax reliefs), and a consultation on the possible combination of income tax and National Insurance (NI), a process which could take several years to complete. A number of measures were specifically aimed at entrepreneurial businesses. The Enterprise Investment Scheme was extended, Entrepreneurs Relief was doubled to apply to gains of up to 10m and the Chancellor announced that 21 new Enterprise Zones, offering tax incentives, discounts and relaxed planning regulations would be created in England. The full Budget details covered a wide range of initiatives, consultations and tax changes. Many were directed at smaller businesses, which the Chancellor singled out as the innocent victims of the credit crunch. The measures included a promise to abolish more business regulations, an increase in the availability of credit from banks to smaller companies, and an increase in the R&D tax credit to 200% in 2011 and 225% in Many small businesses will also be cheered by the news of a three-year moratorium from new regulations for companies with fewer than ten employees, although the Federation of Small Businesses immediately urged the Chancellor to extend the plan to larger companies in an effort to encourage job creation. As chairman of the Professional and Business Services Group, Michael Snyder, senior partner of Kingston Smith, has been in close consultation with the government, advising on key issues vital to continued growth and competitiveness within the sector. It is encouraging to see that the government has taken on board many of the group s concerns and subsequent recommendations in the Budget announcement, including reforming money laundering, promoting the UK s worldleading business arbitration and commercial law services, and reviewing the 50% top rate of income tax. The group looks forward to working with the government to further improve growth within the UK s largest industry sector. For more on the Chancellor s Budget and how it may affect your business, see our 2011 Budget website ( or speak to your client partner. ixbrl: Here to stay From 1 April 2011, all corporation tax payments need to be made electronically and all corporation tax returns must be filed online. This might not seem particularly onerous on the face of it, but alongside mandatory online filing, companies must now deliver their tax computations and annual accounts to HM Revenue & Customs (HMRC) in the new ixbrl electronic format. ixbrl is an electronic tagging system that allows corporation tax returns to be read electronically and for HMRC to collect and analyse the numbers submitted automatically. Key pieces of information are tagged from the UK GAAP taxonomy. (A taxonomy is a dictionary or reference list that sets out the available tags which, in the case of the UK GAAP minimum tagging list adopted by HMRC, currently amounts to 1,253 possible items.) Additional taxonomies exist for companies preparing their accounts under International Financial Reporting Standards. Charities also fall into the regime if they are incorporated and are required to file a corporation tax return. Preparing a tagged set of accounts and tax computation is more time consuming than submitting a paper return and there will be cost implications, particularly for the financial statements. HMRC has indicated that it will adopt a soft landing approach during the first two years of the new regime, and will advise and support people on getting it right. Provided businesses make reasonable attempts to submit ixbrl accounts, HMRC will not issue penalties or reject returns if the new ixbrl requirements are not fully met during this period. However, accounts which do not include certain mandatory tags will not clear HMRC s electronic gateway and incorrect or missing tags may skew HMRC s riskassessment ratios, potentially increasing the risk of a corporation tax enquiry. Our advice is that companies should aim to get this right the first time. Certain very small companies can also use the HMRC gateway to file their accounts with Companies House. It is likely that in the future this will be extended to larger businesses so that companies will file a single set of tagged accounts that both HMRC and Companies House will use. If Kingston Smith already prepares your accounts, tax returns and computations, we will produce all of the documents in ixbrl format using our specialist software. If you have any questions about online filing and ixbrl, ask your client partner or contact Mark Twum-Ampofo on Protect yourself We have seen an increase in HMRC enquiries over the last year. This is a process that demands a lot of support from advisers such as Kingston Smith, and can prove very expensive for a client. For those clients that have taken advantage of the fee protection insurance provided by Kingston Smith, an enquiry is potentially no more than an inconvenience. Our fee protection scheme is designed to cover the costs of representing you in the event of almost any type of HMRC enquiry, for the cost of an annual premium. Our fee protection scheme is designed to cover the costs of representing you in the event of almost any type of HMRC enquiry... We have always taken the view that fee protection insurance is a benefit we provide for our clients to enhance the quality of our overall service. Accordingly, our premiums are kept low and represent extremely good value. We are in the process of finalising the insurance renewal for 2011/12, starting on 1 June 2011, and there will be no substantial increase in the annual premium. If you would like to join the Kingston Smith fee protection scheme, please ask your client partner or manager for details. Alternatively, contact David Benton or Michael Amies on or visit our website at 2 Communiqué Issue

3 Business news Tax news Latin American opportunities We live in an increasingly diversified world where UK businesses have to look further and wider for opportunities to grow revenue and their customer base. Latin America has been talked about as an attractive option, particularly in the financial sector, and for good reason. Brazil is currently the eighth-largest economy in the world by nominal gross domestic product, and it has been predicted to become one of the five largest economies in the world within the next 20 years. But other countries are emerging as potential future markets. The Economist has identified Colombia in the new group of high-growth emerging market countries, while China is considering a US$7bn investment to build a rail line across Colombia to compete with the Panama Canal. Investment from the UK into Latin America is not straightforward and there are the obvious language and cultural barriers, as well as slow bureaucracy affecting some countries. For instance, the World Bank places Brazil 127th in its list of the best places to do business (Mexico is 35th, Peru 36th and Colombia 39th). The same report, incidentally, ranks Colombia as the fifth-best country in the world for protecting investors. If you are thinking of exploring the business opportunities in Latin America, it is essential that you work with local partners who know the market. Kingston Smith s Latin American desk and the member firms of KSi, an association of independent accounting firms located around the world, are here to help. For more information and advice, contact Paul Spindler on Tax and non-domiciles In this year s Budget, the Chancellor announced a number of proposed changes to the way nondomiciles are taxed. This followed a promise in the coalition s Programme for Government to review the taxation of non-domiciled individuals. The biggest change was the announcement that non-domiciled individuals who claim to be taxed on their non-uk income and gains on the remittance basis, and who have lived in the UK for more than 12 years, will be subject to a 50,000 Remittance Basis Charge. This is an increase from the previous 30,000 charge that was applicable if they had been UK-resident for seven of the past nine tax years. The Chancellor added a pledge to remove this tax charge if the non-domiciled individual invests in UK businesses... The Chancellor added a pledge to remove this tax charge if the non-domiciled individual invests in UK businesses, under strict circumstances. He added that he did not plan to introduce any other changes to the taxation of non-domiciles during the current Parliament. Now may be a good time for non-domiciles to review offshore structures and investments, and to at least consider ways of mitigating the risk of potential changes to the tax rules. Kingston Smith would be happy to assist you. Offshore accounts targeted HMRC has said that it plans to double the fines it can impose on individuals who avoid tax due on offshore accounts. From 6 April 2011, the penalties that can be applied by HMRC will range from 100% to 200% of the amount of tax that has been evaded. The new penalty regime is part of a concerted crackdown on offshore accounts as the government attempts to coax offshore money into countries that have a transparent tax regime and which share information with the UK. Tax evaders under scrutiny HMRC has begun to target known tax evaders as part of its new Managing Deliberate Defaulters programme. Under the scheme, HMRC will monitor the activities of individuals and businesses that are known to have deliberately evaded tax in the past to ensure that they are complying with tax requirements and are showing a permanent change in their behaviour. HMRC s monitoring activities could include unannounced inspection visits, requests for specific records, and cross-checking of tax and VAT records with customers and suppliers....hmrc will monitor the activities of individuals and businesses that are known to have deliberately evaded tax in the past... HMRC has also written to over 10,000 self-employed individuals who are claiming tax credits as part of an examination of credits claimed by the self-employed. If HMRC suspects that credits are being claimed falsely, it will ask for evidence to support the claim. Anyone found to be claiming tax credits fraudulently will have to repay the money and could face a fine or, in serious cases, prosecution. Communiqué Issue

4 Tax news (cont) Case study Claim the opportunity HMRC warns of phishing scam There have been reports of a shoal of phishing attempts following the 31 January selfassessment tax return deadline. Thousands of taxpayers have reported receiving an , purportedly from HMRC, which says they are due a tax rebate. A link is provided that clicks through to a replica HMRC website, where taxpayers are asked to provide their credit card or bank account details in order to receive the rebate....taxpayers are asked to provide their credit card or bank account details in order to receive the rebate. HMRC says it has shut down 99 websites that were responsible for sending out similar fake s in the past three months and are warning taxpayers to be vigilant. HMRC will only contact taxpayers who are due a refund in writing by post. Anyone who receives a suspicious that appears to be from HMRC should forward it to phishing@hmrc.gsi.gov.uk, before deleting it permanently. HMRC regularly publishes details of suspicious s on its website at The old adage sweet are the uses of adversity (Shakespeare) is true in life and in tax. Our client had a routine enquiry into their corporation tax return for The enquiry began in March 2009 and took over a year before we negotiated the final adjustments, resulting in additional taxes of 66,000 and a final tax liability of 1.5m for 2006 and our client had anticipated paying additional taxes of 66,000. Instead, we succeeded in securing a tax refund of over 1.3m. Around the same time, our client was in the process of agreeing their research and development (R&D) claim for 2008, 2009 and 2010 with a specialist HMRC officer. The time limit for making an R&D claim is within two years of the end of the accounting period. Some lateral thinking prompted us to ask the HMRC officer to accept a late R&D claim for 2006 and 2007 given that 2007 was under enquiry. The HMRC officer accepted the 2007 claim in full and the 2006 claim in part. Not only did this result in a reduction in the 2007 tax liability from around 900,000 to nil, but it resulted in surplus trade losses of over 1m. The trade losses, however, were unlikely to be used in the immediate future due to R&D claims in subsequent years. The time limit for making a loss carryback claim in respect of the year ended 31 March 2007 expired on 31 March 2009 and therefore our client was out of time. We persuaded HMRC to accept a late loss carryback claim as it had accepted a late R&D claim and it would be inconsistent to do otherwise. Despite HMRC opposition, this was agreed and resulted in a 418,000 reduction in the 2006 corporation tax. To summarise, our client had anticipated paying additional taxes of 66,000. Instead, we succeeded in securing a tax refund of over 1.3m. The ability to identify the opportunities provided by the enquiry, supported by a combination of solid negotiation skills, timing and prompting HMRC to consider a late claim, made this possible. 4 Communiqué Issue

5 Charities news Kingston Smith news New faces at KSAM We are delighted to announce two major new appointments at Kingston Smith Association Management (KSAM), our association management business. Mark Boleat joins KSAM as chairman following the merger of his leading trade association strategy consultancy business, Boleat Consulting, with KSAM. Mark is a former director general of the Association of British Insurers, the UK s largest trade association. Rob Johnson joins KSAM as its new operations director. Rob was previously business services manager at the Johnson Housing Trust. Sir Michael Snyder, senior partner of Kingston Smith, said: Mark and Rob join our association management business with a wealth of knowledge and experience. We re delighted to have them on board. Worrying times for benevolent charities It has not been widely publicised, but the Attorney General has asked the Charity Tribunal to consider whether certain relief of poverty charities are still charitable following the Charities Act 2006 and, in particular, whether they still meet the public benefit test. The relief of poverty charities to be included within this consideration are the charities and benevolent funds, which provide benefits to a restricted class of beneficiary defined by reference to their employment with a particular employer, or membership of a particular society or association, a family relationship or a similar connection. Many charities, both large and small, will be affected if the tribunal does not decide in their favour. Should this happen, the worst case is that the tribunal could decide that any relevant charities are no longer charitable and would either have to broaden their objects and beneficiary base or be removed from the Register of Charities and have their assets transferred to another charity with similar aims. This is not something to be taken lightly by those charities likely to be affected. Interested charities should join forces to try and protect their position by making legal submissions to the Charity Tribunal. Contact Nick Brooks, head of not-for-profit at Kingston Smith, on nbrooks@kingstonsmith.co.uk to seek further clarity. Alternatively, speak to your legal advisers or refer to the Charity Commission website. Good cheer for charities There was good news for the charities sector in this year s Budget, with the Chancellor announcing a range of tax breaks designed to help the sector. The Chancellor said he wanted to make it the norm that people leave 10% of their estate to charity and to that end, a 10% reduction in the inheritance tax rate (IHT)(to 36%) would be available on estates that bequeath at least 10% of their value to charity. The sector welcomed the news that Gift Aid would be dramatically simplified... The sector welcomed the news that Gift Aid would be dramatically simplified with the intention of moving to an online system in The requirement to fill in a Gift Aid form will be removed altogether for small donations, up to a limit of 5,000 per charity per year. Gift Aid benefit limits will also be increased from 500 to 2,500, and the government will hold a consultation on ways of encouraging donations of art to charities. New role for Brooks Nick Brooks, Kingston Smith partner and head of our not-for-profit sector group, has been appointed chairman of the Charity and Voluntary Sector Group of the Institute of Chartered Accountants in England and Wales (ICAEW). As well as providing support and events for the ICAEW s members who work in the voluntary and charities sector, the Charity and Voluntary Sector Group represents ICAEW members views and co-ordinates responses to policy and legislative proposals. Strengthening ties in India Against the backdrop of growing interest in business traffic along the Indo-UK corridor and Kingston Smith s continued association with Indian businesses in the UK, our senior partner Michael Snyder made his annual visit to India earlier this year. Covering the three major Indian cities, Delhi, Mumbai and Bangalore, Michael s visit was aimed at meeting Indian businesses, KSi member firms and the British Deputy High Commissioners in Bangalore and Mumbai. This visit further strengthened Kingston Smith s presence and activity in India and has helped increase its visibility as a preferred adviser for inward investments and corporate finance from India to the UK. Communiqué Issue

6 Private client services Life assurance and IHT planning IHT will affect all UK residents who have estates worth over 325,000 or 650,000 for a married couple at the time of death. This is not a tax that the deceased will pay, as it is normally paid after death. Therefore, there is sometimes a reluctance to take action to mitigate the tax for the sake of one s beneficiaries. The tax can be lowered by reducing the value of an estate, essentially by increasing expenditure or by making significant gifts to others. So where does life assurance come into IHT planning? If you make a significant gift from capital to an individual or to an absolute trust, the IHT liability will remain in whole or in part for seven years after the gift has been made. Life assurance covers the risk that the individual making the gift dies before the end of the seven years. The level of life cover would equal the calculated tax liability for each year. A seven-year term assurance can also be used to cover death within seven years of a chargeable lifetime transfer made to a discretionary trust. If the gift is a property, life cover prevents the need to sell the property should the individual making the gift die before the end of the seven years. Life assurance covers the risk that the individual making the gift dies before the end of the seven years. There are two other important situations where life assurance should be considered. If you are married to someone who is not UK domiciled or if you live as an unmarried couple, the inter-spousal exemption will not apply. This means that a significant IHT liability would arise on the death of the first partner, which could necessitate the sale of the family home if life cover is not in place. Planning for school and university fees The topic of university funding has been almost daily news in the media since the coalition government s decision to increase the tuition fee cap from 3,000 to 9,000 per annum. Now is an important time to start thinking about how to plan effectively for your children or grandchildren s education. The use of an offshore investment bond provides a tax-efficient route to achieving this goal. For example, grandparents keen to help fund both school and university fees could invest in an offshore investment bond held in an Absolute Trust for the benefit of a child. This initial investment is treated as a Potentially Exempt Transfer (PET) and could therefore be subject to IHT should the settlor die within the first seven years of making the investment. All growth within each segment of the offshore investment bond is generally tax free and no personal tax arises until encashment is more than 5% per annum. When school fees are due the relevant amount is encashed and the proceeds are assessed against the beneficiary for income tax purposes. However, because the beneficiary is a child or university student there is unlikely to be any tax due. At age 18 the bond is assigned, without any tax charge, to the child and encashed by him/ her as and when the university fees are due. Again the encashment is assessed on the beneficiary for income tax purposes. For 2011/2012, the grandchild s personal allowance of 7,475 can be used to offset any gain. After that, a 10% starting rate for savings income is payable on any excess up to 2,560, while any excess that falls within the basic-rate threshold is taxed at 20%. Now is an important time to start thinking about how to plan effectively for your children or grandchildren s education. Parents can assist with the funding of university fees by taking out an offshore investment bond in their own name and assigning the bond to the child at age 18. The student would then encash the bond when required. As the assignment is for education and maintenance purposes, it is deemed to be an exempt transfer and is immediately out of the estate for IHT purposes. This strategy is tax efficient in terms of both income tax and IHT, and the choice of underlying investment within the bond is considerable. The other use of life assurance is to cover the liability that remains on the estate after accounting for the effect of any other IHT planning. Indeed, if you do not wish to take steps to deplete your assets and the premiums are affordable, life assurance in trust for your beneficiaries is the simplest way to create a tax exempt fund to cover the tax, allowing the full estate to pass to your beneficiaries. For this purpose, a whole life policy will be used without a defined term to ensure that funds are produced at the time the tax liability arises. 6 Communiqué Issue

7 For example, this is the contribution history of an individual earning over 130,000 in one of the three previous tax years who is caught by the anti-forestalling rules: 2008/09 = 40, /10 = 20, /11 = 20,000 This is what can be paid in 2011/12 as employer and/or personal gross pension contributions using the carry-forward facility: Tax year Actual input Allowance Unused allowance 2008/09 40,000 50,000 10, /10 20,000 50,000 30, /11 20,000 50,000 30, /12 50,000 50,000 Total 120,000 Buy-to-let finance market update There has been a significant improvement in the availability of finance in the buy-to-let market compared to a year ago. Currently, clients can choose from over 300 products offered by 32 lenders, with rates starting as low as 2.74% and funds available for up to 85% of the property value. Growing demand for rental accommodation is behind this improvement, as first-time buyers struggling to take their first step onto the property ladder leave landlords less concerned that their properties may be unoccupied. In 2010, this demand led to an average rise of 7% in rental values across the UK and a 13% rise in London. Let to buy is also becoming increasingly common as homeowners opt to move to a new property and let their current home rather than sell it, especially as the ability to claim the capital gains tax exemption on two properties for up to three years survived the Budget. This can be useful either as a long-term property investment that enables the client to retain two homes or simply to break up a difficult property chain in the short term. In the current market, it is important to understand fully the fee structuring, as well as the rates and rental criteria. At first sight, fees may look punitive, but on investigation there is logic behind the structures. In many situations the lower rate and higher fees work better for potential landlords looking to ensure the rent covers the mortgage payments. A lender s terms may be a two-year fixed rate of 3.99% with an arrangement fee of 3.5%. This can also be looked at as an annual rate of 5.74% if the fee is paid over the first two years. At first sight, fees may look punitive, but on investigation there is logic behind the structures. Another lender may have a two-year fixed rate of 4.49% with a fixed fee of 1,249. Again, assuming the fee is paid over the two years the overall rate payable will depend on the amount borrowed. This highlights that, depending upon loan size and client preference, the full market needs to be considered. A range of fixed and variable rates are currently available, with a choice of fee structures. To explore your options fully, please contact Martin Worland at Kingston Smith Financial Advisers on Maximise your pension contributions The new annual pension contribution allowance is 50,000, with it possible to claim tax relief at the highest marginal rate paid (up to 50%) on personal contributions of up to 100% of earnings. It is also possible to carry forward any unused allowances (maximum 50,000 per annum) from the last three tax years. In addition, with careful manoeuvring of pension input periods (PIPs), it may be possible to bring forward the annual allowance of 50,000 from the next tax year (i.e. 2012/13) to the current year, making a total contribution of 170,000 available in 2011/12. This assumes the individual has taxable earnings of at least 170,000. To obtain 50% relief on the whole amount, if paid personally, total taxable income in 2011/12 would need to exceed 320,000. If paid by an employer, corporation tax relief should be available, with the individual not being liable to tax if taxable earnings exceed 170,000. There will also be no National Insurance Contributions (NICs) to pay on this pension contribution. It should be borne in mind that the standard lifetime allowance will be reduced from 1.8m to 1.5m from 6 April 2012 and will be held at this level until further notice. The lifetime allowance is the maximum value of pension benefits, when crystallised, that can be accrued without the individual suffering a tax penalty. It will be possible to apply for fixed protection before 5 April 2012 to maintain the lifetime allowance at 1.8m, but no further pension contributions can then be made. To gain maximum tax efficiency and to avoid unexpected tax charges, professional advice is essential in order to understand the options you have in respect of contributions and the timing of taking benefits. Kingston Smith Financial Advisers is a trading name of Blacktower Financial Advisers Limited, which is authorised and regulated by the Financial Services Authority. Communiqué Issue

8 HR news The Employer s Charter The Department for Business, Innovation and Skills (BIS) has published an Employer s Charter which, it says, is intended to dismiss some of the myths about what employers can and can t do in managing their workforce. The BIS believes that there needs to be a better balance between the protection of employees and the ability of businesses to operate effectively, and that guidance on employment law often concentrates too heavily on the rights of employees. The charter says that as long as employers act fairly and reasonably, they are entitled to: ask an employee to take annual leave at a time that suits the business contact a woman on maternity leave and ask when she plans to return make an employee redundant if the business takes a downward turn ask an employee to take a pay cut withhold pay from an employee when he/ she is on strike ask an employee whether he/she would be willing to opt out from the 48-hour limit in the Working Time Regulations reject an employee s request to work flexibly if there is a legitimate business reason talk to employees about their performance and how they can improve dismiss an employee for poor performance stop providing work to an agency worker (as long as they are not employed by the employer) ask an employee about his/her future career plans, including retirement. Copies of the charter can be downloaded from the BIS website at The Professional and Business Services Group, chaired by Michael Snyder, senior partner of Kingston Smith, has been working with BIS and other government officials to bring about much-needed change to current employment law regulations. The group has specifically highlighted the need for guidance on stress-at-work claims and reform of the tribunal system, and is waiting for an announcement from the government on these recommendations. Dates to note 11 May Keeping yourself legal A seminar aimed at entrepreneurial businesses will look at the new pensions rules for high earners and what companies need to do to prepare. 16 May How to maximise the value of your database Our charities experts will discuss how voluntary sector organisations can maximise the value of their database. 17 May Stuart Morley s view of the economic outlook for the property sector What lies in store for the property sector? Stuart Morley, Head of Research at GVA Grimley, looks at the economic landscape. 24 May 75-minute guide to accounts for non-accountants This is a repeat of our very popular seminar, to be held at the Redhill office. 31 May Deadline for issuing P60 forms to employees for the 2010/11 tax year. 7 June Doubling the value of your business The directors of Devonshire Corporate Finance Ltd will explain how careful planning and knowledge can increase the value of your business as you prepare to sell. To be held at Marygreen Manor, Brentwood. 16 June Minimising the risk of acquisitions Thinking of acquiring another business? This seminar offers key tips and case studies of recent transactions. 29 June How to increase voluntary income: Part 1 A seminar for the not-for-profit sector looks at ways of increasing voluntary income. To be held at the Holiday Inn, Brentwood. 6 July P11D forms due. 19 July Class 1A NIC due. Seminars to be held at the City office unless another venue is specified. These are a selection from the extensive range of events we organise for clients. For a full list, see Contact us City Devonshire House 60 Goswell Road London EC1M 7AD T Hayes Middlesex House 800 Uxbridge Road Hayes, Middlesex UB4 0RS T New Malden Kingston Smith Financial Advisers 80 Coombe Road New Malden, Surrey KT3 4QS T Redhill Surrey House High Street Redhill, Surrey RH1 1RH T Romford Orbital House 20 Eastern Road Romford, Essex RM1 3PJ T St Albans 105 St Peter s Street St Albans, Herts AL1 3EJ T West End 141 Wardour Street London W1F 0UT T For further information on Kingston Smith LLP and our services please visit our website Views expressed in Kingston Smith LLP Communiqué are those of the contributors. No responsibility for loss occasioned by any person acting or refraining from action as a result of the material in this newsletter can be accepted by the LLP or any of its associated concerns. Kingston Smith LLP is registered to carry out audit work and regulated for a range of investment business activities by the Institute of Chartered Accountants in England & Wales. A member of KS International. Kingston Smith Financial Advisers is a trading name of Blacktower Financial Advisers Limited, which is authorised and regulated by the Financial Services Authority. Devonshire Corporate Finance Limited is authorised and regulated by the Financial Services Authority. HR Insight Limited is authorised and regulated by the Financial Services Authority. Occasionally we may wish to contact you to keep you informed of similar initiatives related to Kingston Smith LLP and its associated companies. If you do not wish to receive this publication or any other information in the future, please us at pd@kingstonsmith.co.uk stating unsubscribe with the name of the publication, your name and the postal address to which the issue was sent, or telephone Alternatively you can write to us: Devonshire House, 60 Goswell Road, London EC1M 7AD. Kingston Smith LLP 2011

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