Please contact me should you wish to discuss any of the points raised in the attached response.
|
|
- Hubert Lane
- 6 years ago
- Views:
Transcription
1 16 April 2008 Our ref: ICAEW Rep 44/08 Adetutu Odutola Markets Policy The Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS By Dear Ms Odutola FSA DP08/1 A review of the Structure of the Listing Regime The Institute of Chartered Accountants in England and Wales is pleased to respond to your request for comments on Discussion Paper 08/1 A review of the Structure of the Listing Regime. Please contact me should you wish to discuss any of the points raised in the attached response. Yours sincerely Katerina Joannou Manager, Capital Markets Policy Corporate Finance Faculty T +44 (0) F +44 (0) E katerina.joannou@icaew.com cc Bhavika Chauhan, HM Treasury (para 6 in respect of FSA DP08/1 para 6.11) David Moran, HM Revenue & Customs (para 6 in respect of FSA DP08/1 para 6.11) Chartered Accountants Hall PO Box 433 Moorgate Place London EC2P 2BJ T +44 (0) F +44 (0) DX DX 877 London/City
2 ICAEW Representation ICAEW REP 44/08 A REVIEW OF THE STRUCTURE OF THE LISTING REGIME Memorandum of comment submitted in April 2008 by The Institute of Chartered Accountants in England and Wales, in response to Financial Services Authority discussion paper A review of the Structure of the Listing Regime published in January 2008 Contents Paragraph Introduction 1 Who we are 2-3 Major points 4-9 Responses to specific questions Chartered Accountants Hall PO Box 433 Moorgate Place London EC2P 2BJ T +44 (0) F +44 (0) DX DX 877 London/City
3 INTRODUCTION 1. The Institute of Chartered Accountants in England and Wales (the ICAEW) welcomes the opportunity to comment on the discussion paper A review of the Structure of the Listing Regime published by the Financial Services Authority (the FSA). WHO WE ARE 2. The ICAEW operates under a Royal Charter, working in the public interest. Its regulation of its members, in particular its responsibilities in respect of auditors, is overseen by the Financial Reporting Council. As a world leading professional accountancy body, the ICAEW provides leadership and practical support to over 130,000 members in more than 140 countries, working with governments, regulators and industry in order to ensure the highest standards are maintained. The ICAEW is a founding member of the Global Accounting Alliance with over 700,000 members worldwide. 3. The ICAEW s Corporate Finance Faculty (the Faculty) is a network of over 6,000 corporate finance professionals. This response draws on the expertise of Faculty members, which include sponsors and reporting accountants as well as the wider experience of the ICAEW in corporate governance, taxation and company law. MAJOR POINTS Support for the initiative 4. The FSA s discussion paper on the structure of the Listing regime cites the evolution in global markets and the changing EU legislative structure as key reasons for the review. We agree it is sensible to take stock of the current position and are supportive of efforts to make the regulatory framework for listing easier to understand. We also agree with the FSA s objective to ensure that the Listing regime is optimally structured to support an appropriate balance between investor protection and maintaining the competitiveness of the UK capital markets for both UK and overseas issuers. 5. We feel that investor appetite for some of the proposals is, in some cases, unclear. We believe that more evidence is needed of the preferences of issuers and investors for Secondary Listing for UK companies, a sponsor regime for GDRs and trading on multilateral trading facilities. 6. The FSA s discussion paper considers two options for restructuring the Listing segments and as explained later in this response, we support option 2. If, however, the FSA is persuaded by response to choose option 1 we strongly believe that a fuller understanding is needed of the potential tax implications of option 1 prior to its adoption. Option 1 envisages a single Listing segment for equity securities with super-equivalent standards, under which certain securities would lose their current listed status. The tax system has built many of its exemptions and reliefs on the basis that companies are, or are not, listed and, in many cases, financial advice is driven by the tax consequences. Past plans and decisions will have been made in the light of the advantages or disadvantages of listing (or not), both from the point of view of companies but also from the point of view of investors. Potential unintended consequences for the tax system from a change to the Listing regime would need to be identified and a future consultation on the two options should, in our view, be accompanied by an in-depth review
4 and impact assessment of the proposals by HM Revenue & Customs, with the collaboration of HM Treasury. Major points 7. We consider that the UK super-equivalent Listing standards should be retained and, in the interests of quality and consistency, they should continue to be set by the FSA. 8. We consider option 2 for restructuring of the Listing segments to be optimal. This option would retain the status quo of the existing two-tier structure but with modernised labels. The FSA should raise awareness of the labels to reinforce the distinction between super-equivalent and directive minimum standards and, in the interest of investor protection, we consider that greater clarification should be provided as to the customary levels of due diligence for the different Listing segments. 9. We consider that the analysis of the GDR market is a critical factor in deciding whether to require appointment of a sponsor. To the extent that it is a wholesale market for professional investors we do not consider a sponsor regime to be appropriate. The GDR market is highly mobile and, in the absence of failure in the current regime, any moves to impose the requirements of a sponsor could reduce the attractiveness of the London market. If ongoing analysis shows that there are retail investors of GDRs, we believe that additional regulation would be needed for investor protection and that this should be considered at the European level. This review provides a good opportunity to clarify the differences between the Primary Listing and GDR regimes in terms of regulation and market practice for due diligence. RESPONSES TO SPECIFIC QUESTIONS Q1: Do you consider that the UK super-equivalent Listing standards should be retained? 10. The success of the UK s Listing regime is dependent on London being an attractive place for UK and foreign issuers seeking a listing. 11. Current statistics show a decline in numbers of UK companies seeking a Primary Listing. We believe that this can be partly attributed to the fact that, for some companies, the super-equivalent standards are seen to be too onerous and costly. For a number of such companies AIM has offered a preferred alternative. Notwithstanding this trend, we do not believe that the super-equivalent standards should be phased out. A move to a market which is purely directive minimum would be a major change; it could substantially alter the UK markets and could adversely affect investor confidence. Moreover, the market signalled its acceptance of the current regime very recently (2005) and feedback from ICAEW members indicates continuing support for the current regime. We believe that the super-equivalent standards work to provide investor protection, reduce the cost of capital to companies and enhance the London Listing brand. 12. We thus support the retention of the UK super-equivalent Listing standards. Indeed if these were not retained, it is possible that exchanges (or other bodies) would seek to apply super-equivalent standards within their admission rules which we do not consider would be desirable.
5 Q2: Do you consider that the super-equivalent Listing standards should continue to be set by the FSA or should they be determined by the market (exchanges, trade associations or other independent body)? 13. We would be concerned if there were to be a transfer of super-equivalent standard setting powers to one or more exchanges or trade associations, which could lead to a fragmented regime and concerns over independence or bias within the standard setter(s). Such factors could impair investor confidence. 14. We believe that the super-equivalent Listing standards should be set by an independent body to avoid a fragmented regime and provide greater assurance of quality. Furthermore we believe it is optimal that such a standard setting body should be the same as the one that supervises the directive minimum requirements so that any interpretation of the two sets of standards can be applied in an appropriate and, where relevant, consistent manner. 15. Accordingly, we believe that the FSA, as the competent authority for Listing in the UK, is best placed to continue to set the super-equivalent Listing standards, a role it assumed in 2005 when the Prospectus Directive was implemented and after a wholesale review of the Listing Rules. At the time the market accepted that this was in the interests of investor protection. This has the advantage that it permits the wealth of knowledge and expertise within the UK Listing Authority team to be utilised in the future. Q3: Should we allow equity securities to be admitted to the Official List if they are only to be admitted to trading on a MTF operated by an RIE or an investment firm and not on a Regulated Market of an RIE? If so, on what basis? 16. The proposal is that a Primary Listing could be accompanied by admission to trading on platform that is not regulated. Such a platform might be a multilateral trading facility (MTF) operated by a Recognised Investment Exchange (RIE) or an investment firm. It is important to reinforce the point that unregulated does not mean unsupervised. 17. We believe that a distinction may be drawn between Listing and trading. If a company complies with the super-equivalent standards associated with a Primary Listing, then its securities should be capable of being admitted to the Official List irrespective of where the shares are traded or to be traded. Accordingly we would support a proposal to permit Official List securities to be traded on an unregulated platform of an RIE providing it is not a way for issuers to avoid any obligations of listed markets. If the rules for admission and continuing obligations apply, this will ensure that trading of Primary Listed securities on an unregulated platform will not reduce investor protection. 18. However some of our contributors felt that the timing of introducing this option may not be optimal: The objective of this review is to remove the perceived risk of confusion among investors and issuers about the current segments of the Listing regime. It is perhaps not the time to introduce new trading options which could add to complexity especially if unregulated and regulated platforms have different regulatory frameworks.
6 Q4: Which of the options described above do you consider to be optimal? Please provide the reasons for your chosen option. 19. We acknowledge that the term listed is used loosely by the market and the media, often to refer to securities that are not on the Official List, including securities traded on AIM. For this reason we believe that it is not pragmatic to reclaim the term listed and apply it only to the super-equivalent regime, as envisaged under option It is also realistic to expect that depriving GDRs of the listed label as envisaged under option 1, will reduce the attractiveness of issuing GDRs in the UK. Furthermore removing the listed label from issuers with a Secondary Listing has uncertain implications for the Professional Securities Market. 21. We believe instead that focus should be placed on promoting the distinction in the respective obligations to which issuers are subject in super-equivalent and directive minimum regimes. For this reason we prefer option 2 as it would help raise understanding of that distinction: Tier 1 securities being those that are subject to a super-equivalent regime while Tier 2 securities being those that follow directive minimum regulation. 22. When distinguishing between the two tiers which are proposed, in addition to setting out the differences between the applicability of rules (as illustrated on page 21 of the discussion paper), it may also be worth identifying the different levels of due diligence that are customarily performed on issuers of Primary as compared with Secondary Listings and GDRs to build investor awareness. Q5: What are your views about opening up Secondary Listing for UK incorporated companies? 23. UK companies, unlike overseas companies, are not currently eligible for a Secondary Listing. In contrast, other EU companies can access a directiveminimum Listing regime in the UK as well as in their local market. This situation is due perhaps to an historic assumption that UK investors prefer to invest in UK blue-chip companies but, in theory at least, the option of a Secondary Listing is currently available to a UK company where it has a holding company registered in the Channel Islands. However such a company would not be eligible for inclusion in the FTSE index series, which is presently only open to companies with a Primary Listing. 24. Some of our contributors believe that UK companies should have the choice of both methods of listing and that there is no reason to restrict a UK company s ability to list in the manner in which overseas companies can come to the UK and UK companies can list overseas. 25. Opening up the Secondary Listing route to UK companies would provide UK issuers with another alternative to a Primary Listing, an existing alternative being an admission to trading on AIM. The extent to which UK companies currently opt for a directive minimum listing in another EU market is unclear but adopting the directive minimum regime of a Secondary Listing would be a fairly radical change for UK companies. For a Secondary Listing, issuers do not require a sponsor whereas AIM companies require a nominated adviser at all times a regime which is not far off the sponsor regime and which is an ongoing relationship.
7 26. There are two arguments to counter the equality argument for allowing UK companies a Secondary Listing. The pool of liquidity and investor base available to Secondary Listed companies is not as great as for Primary Listed companies which attract tracker funds. Moreover if UK issuers opt for a Secondary Listing in order to avoid the requirements of the sponsor regime, this increase in choice could be at the expense of investor protection, as explained in the next paragraph. 27. Article 44 of Consolidated Admissions and Reporting Directive (CARD) provides that an applicant must have published or filed its annual accounts in accordance with national law for the three financial years preceding the application for official listing. It goes on to provide that the competent authorities may derogate from this condition where such derogation is desirable in the interests of investors and where the competent authorities are satisfied that investors have the necessary information to arrive at an informed judgment on the company and the shares for which listing is sought. Article 44 of CARD is implemented in LR 6.1.3, but nowhere else. All other requirements of CARD are implemented in chapter 2 of the Listing Rules and hence apply to Secondary Listings via , or are directly implemented in chapter 14 of the Listing Rules. Thus, technically, the chapter 14 requirements are slightly less than the directive minimum because the requirements of Article 44 of CARD do not apply to Secondary Listings. 28. Given that it is unclear if there is investor appetite for this level playing field with overseas companies and for a listed alternative to AIM, we would suggest that the status quo is maintained until the preferences of issuers (including their attitude to the prospect of not being included in the FTSE index series) and influencing investors have been established and thorough consideration has been given to the level of investor protection which should be applied to directive minimum UK company listings, including appropriate levels of due diligence. Q6: What are your views on how the provisions we have described above under core requirements should apply to overseas Primary Listed companies? 29. The proposal is to apply to overseas Primary Listed companies three core requirements of the super-equivalent regime: Combined Code; pre-emption rights; and Takeover Code, which would level the playing field for issuers with Primary Listings. 30. An objective of the proposals in the discussion paper is to create clarity for investors regarding a Primary Listing. In the discussion paper attention is drawn to the FTSE UK index series practice note which refers to criteria currently taken into consideration for inclusion of an overseas company in the FTSE UK index series. The criteria are compliance with the UK Combined Code, the Takeover Code and pre-emption rights. The FSA states: If all primary equity issuers were subject to exactly the same requirements, whether they were UK companies or overseas companies, that could give further clarity to the Primary Listing segment, and remove one possible source of uncertainty and confusion. (FSA DP08/1 para 6.19) 31. It would be interesting to know how many overseas companies are motivated by the desire for inclusion in the FTSE index series and seek to conform to these requirements voluntarily and are permitted to do so by their home jurisdiction. However, we understand that the FTSE practice note can be applied with some discretion and on a case by case basis by the Nationality Committee of the FTSE
8 thus, while of interest, it should not be used as a basis for deciding how to apply super-equivalent Listing standards for overseas companies. 32. Other considerations for this debate are whether there is evidence of sufficient demand for applying these core requirements and the impact on the competitiveness of the UK market. 33. Requiring overseas companies to adopt the UK Combined Code may add certainty and visibility and would result in a common set of standards for Primary Listings. We have encountered support among members for this proposal but, as may be seen in the paragraphs that follow, other contributors have expressed uncertainty at its potential effectiveness. Moreover the EU may see this proposal as running in a different direction to that envisaged in the company law directives. We believe there is a case for in-depth consultation on this point. 34. Those who support the proposal consider that the current corporate governance disclosures for overseas companies are confusing and are simply a two-stage way of disclosing of whether or not they comply with the UK standards. Rather than companies being required to confirm that they comply with the requirements in their country of origin and then to describe how such requirements differ from the UK, those in support consider that it would be preferable for overseas companies to comply or explain against the UK Combined Code. This approach is thought to be less confusing for investors and would enable better comparison with UK companies of a similar sector or of a similar size. 35. Those who do not support the proposal believe that the current corporate governance disclosures for overseas companies can result in more revealing and transparent disclosures than might a tick-box approach under comply or explain, if those companies adopt the procedures and structures recommended in the Code without properly addressing the underlying governance issues. Moreover, requiring overseas companies to adopt the Code assumes that it is appropriate in all overseas jurisdictions and could open up the possibility of UK companies listing overseas being required to fully comply with local codes. Finally there is also a concern that the proposal will create an undesirable hurdle for foreign issuers wishing to list in the UK. 36. Pre-emption rights cannot be enforced on an overseas company if this is contrary to the local law of the country in question. However this should not necessarily preclude a super-equivalent Listing. Again, overseas companies could be required to comply or explain against the UK requirements. Where there is a need to explain, the company should provide very clear disclosure and perhaps include standard risk warnings, so that investors would have a clear understanding of their investment. 37. We agree with the analysis that it would not be possible for the FSA to impose application of the UK Takeover Code on overseas Primary Listed companies. However the FSA could require companies to make it clear whether or not the company is subject to the UK Takeover Code and, if not, full disclosure should be provided as to what takeover regulations do apply so that investors can understand the relevant risks.
9 Q7: Should we require the appointment of a sponsor for a transaction involving the issuance of GDRs? If not, are there any other responses to the significant growth in GDRs that are necessary? 38. Like the wholesale debt market the GDR market tends to be transactionallydriven. It is one for professional investors with a lighter-touch regulatory environment and is highly mobile. In the absence of evidence of failure in the current regime, any moves to impose the requirement of a sponsor for a transaction involving GDRs could reduce the attractiveness of the London market. 39. A change that is not driven by regulatory failure should be market-led. More feedback should be sought as to whether financial advisers would want the additional due diligence from existing issuers of GDRs in order for them to satisfy sponsor requirements of a Primary Listing and whether investors would prefer issuers to bear the costs of application of a sponsor regime. Initial thoughts from some of our members are that investors would not. 40. A common understanding that the GDR market is a wholesale one is critical to the current regime, where no sponsor is required. Continuous monitoring and analysis of the growth in GDRs should be performed. If future analysis shows that there are retail investors in GDRs, the current light-touch regime should be addressed for investor protection purposes, ideally at the European level. Q8: Do you have views on the labelling options? 41. Consistent with our response to Q4, we believe that the labelling option 2 is preferable. This brings together all the directive minimum securities within the Tier 2 category, which is clearer, in that entities with the same Listing requirements all have the same label. 42. The Tier 1 / Tier 2 labelling system is appropriate in our view as it moves focus away from the terms listing and listed. While those terms are used by the market in a generic way, we believe the most important distinction required is on the respective regulatory standards for each segment. The Tier 1 / Tier 2 system also mean that less emphasis is given to Primary / Secondary distinction; such legacy terms carry more scope for market confusion. 43. In addition we think that the terminology Tier 1 / Tier 2 should be less confusing that the current Primary / Secondary terminology. A Secondary Listing can imply that the issuer has a Primary Listing in its home jurisdiction which, since 2005, has not been a pre-requisite of a Secondary Listing. 44. We consider that the FSA should raise awareness of the new labelling system and use this opportunity to clarify and enhance understanding of the respective levels of regulation and market practice for due diligence. The FSA could consider adopting some Tier 1 / Tier 2 marker within the ticker symbol so that it can be easily apparent to market participants the level of regulation to which a company is subject. Furthermore the FSA could consider requiring a listed company to maintain certain minimum regulatory information on the company s website (including its Tier of Listing) akin to the AIM requirements introduced in 2006, so that investors know how to access such information.
10 The Institute of Chartered Accountants in England and Wales 2008 All rights reserved. This document may be reproduced without specific permission, in whole or part, free of charge and in any format or medium, subject to the conditions that: it is reproduced accurately and not used in a misleading context; the source of the extract or document, and the copyright of The Institute of Chartered Accountants in England and Wales, is acknowledged; and the title of the document and the reference number (ICAEW Rep 44/08) are quoted. Where third-party copyright material has been identified application for permission must be made to the copyright holder.
PROPOSAL FOR A EUROPEAN COUNCIL REGULATION ON THE STATUTE FOR A EUROPEAN PRIVATE COMPANY (SPE)
11 December 2008 Our ref: ICAEW Rep 149/08 Maureen Beresford Corporate Law and Governance Directorate Department for Business, Enterprise and Regulatory Reform 1 Victoria Street London SW1H 0ET By email
More informationREVIEW OF DISCLOSURE OF INFORMATION REQUIREMENTS APPLYING TO OCCUPATIONAL, PERSONAL & STAKEHOLDER PENSION SCHEMES
5 May 2009 Our ref: ICAEW Rep 55/09 Your ref: Tim Found Department for Work and Pensions Private Pensions Policy & Regulation The Adelphi (3rd Floor) 1-11 John Adam Street London WC2N 6HT By email: adelphi.sft@dwp.gsi.gov.uk
More information24 November Our ref: ICAEW Rep 132/08. Your ref:
24 November 2008 Our ref: ICAEW Rep 132/08 Your ref: Mr Steven Leonard Financial Reporting Council 5th Floor Aldwych House 71-91 Aldwych LONDON WC2B 4HN By email: s.leonard@frc-apb.org.uk Dear Steve GOING
More informationThe ICAEW is pleased to respond to your request for comments on Tracing employers liability insurers.
14 September 2010 Our ref: ICAEW Rep 86/10 Your ref: CP 10/13 Trevor Cooke Prudential Insurance Policy Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS Dear Trevor Tracing
More informationPlease contact me should you wish to discuss any of the points raised in the attached response.
11 May 2009 Our ref: ICAEW Rep 61/09 Your ref: Originally submitted on CEIOPS template The Institute of Chartered Accountants in England and Wales (the ICAEW) is pleased to respond to your request for
More informationA Review of the Conceptual Framework for Financial Reporting: draft EFRAG comment letter
24 December 2013 Our ref: ICAEW Rep 179/13 Ms Françoise Flores Chairman EFRAG 35 Square de Meeûs B-1000 Brussels Belgium Dear Françoise A Review of the Conceptual Framework for Financial Reporting: draft
More informationIFRIC D23 - DISTRIBUTIONS OF NON-CASH ASSETS TO OWNERS
9 May 2008 Our ref: ICAEW Rep 59/08 Your ref: Mr. Stig Enevoldsen Chairman Technical Expert Group EFRAG Avenue des Arts 13-14 B-1000 BRUXELLES By email: commentletter@efrag.org Dear Stig IFRIC D23 - DISTRIBUTIONS
More informationICAEW is pleased to respond to your request for comments on ED/2013/1 Recoverable amount disclosures for non-financial assets.
19 March 2013 Our ref: ICAEW Rep 47/13 Your ref: ED/2013/1 Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Dear Hans ED/2013/1 Recoverable amount disclosures
More informationDRAFT GUIDANCE FOR BUSINESS ON THE PREVENTION OF MONEY LAUNDERING
1 June 2007 Our ref: ICAEW Rep 48/07 By email Dear Sirs DRAFT GUIDANCE FOR BUSINESS ON THE PREVENTION OF MONEY LAUNDERING We are pleased to attach the formal response of the Institute of Chartered Accountants
More informationPlease contact me should you wish to discuss any of the points raised in the attached response.
10 September 2010 Our ref: ICAEW Rep 87/10 Your ref: ED/2010/7 Ms Hilary Eastman Senior Technical Manager International Accounting Standards Board 30 Cannon Street London EC4M 6XH Dear Hilary MEASUREMENT
More informationDISCONTINUED OPERATIONS - PROPOSED AMENDMENTS TO IFRS 5
16 January 2009 Our ref: ICAEW Rep 02/09 Your ref: Sir David Tweedie The International Accounting Standards Board 30 Cannon Street London EC4M 6XH By email: commentletters@iasb.org Dear David DISCONTINUED
More informationEQUITY METHOD: SHARE OF OTHER NET ASSET CHANGES (PROPOSED AMENDMENTS TO IAS 28)
28 February 2013 Our ref: ICAEW Rep 41/13 Your ref: ED/2012/3 Mr Hans Hoogervorst International Accounting Standards Board 30 Canon Street London EC4M 6XH Dear Hans EQUITY METHOD: SHARE OF OTHER NET ASSET
More informationAssessment of the suitability of the International Public Sector Accounting Standards for the Member States Public consultation
Our ref: ICAEW Rep 70/12 European Commission - Eurostat Directorate D: Government Finance Statistics Joseph Bech building 5 Rue Alphonse Weicker L-2721 Luxembourg By email: ESTAT-IPSASconsultation@ec.europa.eu
More information11 September Our ref: ICAEW Rep 100/09. Your ref:
11 September 2009 Our ref: ICAEW Rep 100/09 Your ref: Sir David Tweedie Chairman The International Accounting Standards Board First Floor 30 Cannon Street London, EC4M 6XH Dear Sir David FINANCIAL INSTRUMENTS:
More information17 June Our ref: ICAEW Rep 86/13. Mme Françoise Flores Chair European Financial Reporting Advisory Group Avenue des Arts B-1210 Brussels
17 June 2013 Our ref: ICAEW Rep 86/13 Mme Françoise Flores Chair European Financial Reporting Advisory Group 13-14 Avenue des Arts B-1210 Brussels Chère Mme Flores ED/2013/3 Financial Instruments: Expected
More informationCOMPATIBILITY OF THE IFRS FOR SMEs AND THE DIRECTIVES
19 April 2010 Our ref: ICAEW Rep 40/10 Your ref: Ms Françoise Flores Chair Technical Expert Group European Financial Reporting Advisory Group (EFRAG) 35 Square de Meeûs B-1000 Brussels By email: commentletter@efrag.org
More informationImproving engagement practices between companies and institutional investors
20 December 2012 Our ref: ICAEW Rep 190/12 Seamus Gillen Director of Policy ICSA 16 Park Crescent London W1B 1AH By email: policy@icsaglobal.com Dear Mr Gillen Improving engagement practices between companies
More informationICAEW is pleased to respond to your request for comments on Bank Accounts for Bankrupts.
16 February 2012 Our ref: ICAEW Rep 16/12 Sarah O Sullivan Policy Unit The Insolvency Service 21 Bloomsbury Street London WC1B 3QW By email: policy.unit@insolvency.gsi.gov.uk Dear Ms O Sullivan Bank Accounts
More informationrestructure the regime into two segments, Premium and Standard, and eight listing categories.
UKLA Publications Listing Regime FAQs Issue 2 June 2010 The UK Listing Regime has recently been reviewed with the aim of ensuring the regime s structure and issuers responsibilities are clearer. This is
More informationICAEW REPRESENTATION 10/16
ICAEW REPRESENTATION 10/16 Uncertainty over Income Tax Treatments ICAEW welcomes the opportunity to comment on the IASB s DI/2015/1 Uncertainty over Income Tax Treatments, published in October 2015, a
More informationICAEW REPRESENTATION 60/15
ICAEW REPRESENTATION 60/15 DISCLOSURE INITIATIVE: PROPOSED AMENDMENTS TO IAS 7 ICAEW welcomes the opportunity to comment on ED/2014/6 Disclosure Initiative Proposed amendments to IAS 7 published by the
More informationATTRIBUTION OF GAINS TO MEMBERS OF CLOSELY CONTROLLED NON- RESIDENT COMPANIES AND THE TRANSFER OF ASSETS ABROAD
TAXREP 53/12 (ICAEW REP 160/12) ICAEW TAX REPRESENTATION ATTRIBUTION OF GAINS TO MEMBERS OF CLOSELY CONTROLLED NON- RESIDENT COMPANIES AND THE TRANSFER OF ASSETS ABROAD Comments submitted on 22 October
More informationProposed Revisions to IVSC Exposure Draft: The Valuation of Equity Derivatives
30 September 2013 Our ref: ICAEW Rep 134/13 IVSC 1 King Street London EC2V 8AU United Kingdom CommentLetters@ivsc.org Dear Ms Castaneda Proposed Revisions to IVSC Exposure Draft: The Valuation of Equity
More informationICAEW TAX REPRESENTATION 110/17
ICAEW TAX REPRESENTATION 110/17 DELIVERING A TAX CUT FOR SMALL BUSINESSES: A NEW SMALL BUSINESS RATES RELIEF SCHEME FOR WALES ICAEW welcomes the opportunity to comment on the delivering a tax cut for small
More informationICAEW REPRESENTATION 168/14
ICAEW REPRESENTATION 168/14 EFRAG DRAFT ENDORSEMENT ADVICE ON IFRS 15 REVENUE FROM CONTRACTS WITH CUSTOMERS ICAEW welcomes the opportunity to respond to the draft endorsement advice and effects study report
More informationResponse to FSA DP 08/1 A Review of the Structure of the Listing Regime
14 April 2008 Ms Adetutu Odutola Markets Policy Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS 10 Paternoster Square London EC4M 7LS T +44 (0)20 7797 1000 www.londonstockexchange.com
More informationPlease contact me should you wish to discuss any of the points raised in the attached response.
4 February 2014 Our ref: ICAEW Rep 21/14 Your ref: ED/2013/9 Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Dear Hans ICAEW is pleased to respond to
More informationEmployer Debt (Section 75 of the Pensions Act 1995) Consultation on draft regulations draft ICAEW response
19 November 2009 Our ref: ICAEW Rep 118/09 Your ref: Mike Rochford Department for Work and Pensions 7 th Floor Caxton House Tothill Street London SW1H 9NA Dear Mr Rochford Employer Debt (Section 75 of
More informationICAEW REPRESENTATION 96/15
ICAEW REPRESENTATION 96/15 EFRAG draft endorsement advice on IFRS 9 Financial Instruments ICAEW welcomes the opportunity to respond to the draft endorsement advice and effects study report on IFRS 9 Financial
More informationICAEW REPRESENTATION 92/16
ICAEW REPRESENTATION 92/16 Exposure Draft 60 Public Sector Combinations ICAEW welcomes the opportunity to comment on the Public Sector Combinations exposure draft published by the International Public
More information22 August Our ref: ICAEW Rep 111/13. Angela Linghorn-Baker Probate Service, WG 09 Royal Courts of Justice Strand London WC2A 2LL
22 August 2013 Our ref: ICAEW Rep 111/13 Angela Linghorn-Baker Probate Service, WG 09 Royal Courts of Justice Strand London WC2A 2LL By email: ncpr@hmcts.gsi.gov.uk Dear Ms Baker Probate Rules ICAEW welcomes
More informationCONSULTATION DRAFT: SIR 2000 INVESTMENT REPORTING STANDARDS APPLICABLE TO PUBLIC REPORTING ENGAGEMENTS ON HISTORICAL FINANCIAL INFORMATION
3 December 2010 Our ref: ICAEW Rep 134/10 Steven Leonard, Project Director APB, 5 th Floor, Aldwych House 72-91 Aldwych London WC2B 4HN Dear Steven CONSULTATION DRAFT: SIR 2000 INVESTMENT REPORTING STANDARDS
More informationIntroduction 1-3. Who we are 4-6. Key point summary / Major points Responses to specific questions 13-48
TAXREP 57/11 ICAEW TAX REPRESENTATION VAT: COST SHARING EXEMPTION Comments submitted in September 2011 by ICAEW Tax Faculty in response to the HM Revenue & Customs consultation document, VAT: Cost Sharing
More informationICAEW REPRESENTATION 196/16
ICAEW REPRESENTATION 196/16 Consultation Paper: Public Sector Specific Financial Instruments ICAEW welcomes the opportunity to comment on the Public Sector Specific Financial Instruments consultation published
More informationICAEW is pleased to respond to your request for comments on Debt management (and credit repair services) guidance.
15 September 2011 Our ref: ICAEW Rep 84/11 Aaron Berry Office of Fair Trading Fleetbank House 2-6 Salisbury Square London EC4Y 8JX By email: dmguidance-consult@oft.gsi.gov.uk Dear Aaron Debt management
More informationICAEW REPRESENTATION 166/16 TAX REPRESENTATION
ICAEW REPRESENTATION 166/16 TAX REPRESENTATION Lease Accounting Changes: Tax Response ICAEW welcomes the opportunity to comment on the discussion draft Lease Accounting Changes: Tax Response published
More informationCONCEPTUAL FRAMEWORK FOR FINANCIAL REPORTING: THE REPORTING ENTITY
16 July 2010 Our ref: ICAEW Rep 67/10 Your ref: ED/2010/2 Sir David Tweedie Chairman International Accounting Standards Board 30 Cannon Street London EC4M 6XH Dear Sir David CONCEPTUAL FRAMEWORK FOR FINANCIAL
More informationICAEW REPRESENTATION 191/16
ICAEW REPRESENTATION 191/16 Practice Note 20 (Revised): The Audit of Insurers in the United Kingdom ICAEW welcomes the opportunity to comment on the Practice Note 20 (Revised): The Audit of Insurers in
More informationACCOUNTING FOR FINANCIAL INSTRUMENTS AND REVISIONS TO THE ACCOUNTING FOR DERIVATIVE INSTRUMENTS AND HEDGING ACTIVITIES
30 September 2010 Our ref: ICAEW Rep 101/10 Your ref: 1810-100 Technical Director Financial Accounting Standards Board 401 Merritt 7 PO Box 5116 Norwalk Connecticut 06856-5116 USA Dear Sir / Madam ACCOUNTING
More informationICAEW REPRESENTATION 09/18
ICAEW REPRESENTATION 09/18 Accounting for Revenue and Non-Exchange Expenses ICAEW welcomes the opportunity to comment on the Accounting for Revenue and Non-Exchange Expenses consultation paper published
More informationICAEW REPRESENTATION 07/18
ICAEW REPRESENTATION 07/18 Occupational Pension Schemes (Master Trusts) Regulations 2018 ICAEW welcomes the opportunity to comment on the Occupational Pension Schemes (Master Trusts) Regulations 2018 published
More informationICAEW is pleased to respond to your request for comments on the proposed insolvency rules
28 March 2011 Our ref: ICAEW 39/11 (ME Rep 03/11) DIFC Courts Dubai International Financial Centre Ground Level, Building 4 The Gate District PO Box 211724, Dubai, UAE Dear Sir Public Consultation for
More informationFINANCE BILL 2012 DRAFT CLAUSES: INFORMATION POWERS
TAXREP 11/12 ICAEW TAX REPRESENTATION FINANCE BILL 2012 DRAFT CLAUSES: INFORMATION POWERS Comments submitted in February 2012 by ICAEW Tax Faculty to HM Revenue & Customs in response to the draft Finance
More informationRevised scheme for registration of charges created by companies and limited liability partnerships: proposed revision of Part 25, Companies Act 2006
30 September 2011 Our ref: ICAEW Rep 94/11 Anne Scrope, Business Environment, Department for Business, Innovation and Skills, Spur 2, 3rd floor, 1 Victoria Street, London SW1H 0ET By email: anne.scrope@bis.gsi.gov.uk
More information22 December EFRAG 35 Square de Meeûs B-1000 Brussels Belgium. Dear Sirs GOODWILL AND IMPAIRMENT ICAEW REP 197/16
22 December 2016 EFRAG 35 Square de Meeûs B-1000 Brussels Belgium Dear Sirs GOODWILL AND IMPAIRMENT ICAEW REP 197/16 ICAEW welcomes the opportunity to comment on the EFRAG/ ASBJ joint study entitled What
More informationRESEARCH AND DEVELOPMENT TAX CREDITS: RESPONSE AND FURTHER CONSULTATION
TAXREP 46/11 ICAEW TAX REPRESENTATION RESEARCH AND DEVELOPMENT TAX CREDITS: RESPONSE AND FURTHER CONSULTATION Comments submitted in August 2011 by the Tax Faculty of the Institute of Chartered Accountants
More informationTAXREP 39/11 ICAEW TAX REPRESENTATION CONSULTATION ON THE ABOLITION OF 36 TAX RELIEFS
TAXREP 39/11 ICAEW TAX REPRESENTATION CONSULTATION ON THE ABOLITION OF 36 TAX RELIEFS Comments submitted in August 2011 by the Tax Faculty of the Institute of Chartered Accountants in England & Wales (ICAEW)
More informationContents Paragraph Introduction 1-4. Who we are 5-7. Response to consultation 8. Appendix Ten Tenets for a Better Tax System 1
TAXREP 40/12 (ICAEW REP 119/12) ICAEW TAX REPRESENTATION UNAUTHORISED UNIT TRUSTS ANTI-AVOIDANCE Comments submitted on 20 August 2012 by ICAEW Tax Faculty in response to HMRC consultation document High-risk
More informationTAXREP 22/14 (ICAEW REPRESENTATION 56/14)
TAXREP 22/14 (ICAEW REPRESENTATION 56/14) ICAEW TAX REPRESENTATION REVIEW OF EXISTING VAT LEGISLATION ON PUBLIC BODIES AND TAX EXEMPTIONS IN THE PUBLIC INTEREST ICAEW welcomes the opportunity to comment
More informationTHE EUROPEAN COMMISSION S GREEN PAPER ON POLICY OPTIONS FOR PROGRESS TOWARDS A EUROPEAN CONTRACT LAW FOR CONSUMERS AND BUSINESSES
26 November 2010 Our ref: ICAEW Rep 135/10 Andrew Lee Ministry of Justice 102 Petty France London SW1H 9AJ By email: andrew.lee@justice.gsi.gov.uk Dear Mr Lee THE EUROPEAN COMMISSION S GREEN PAPER ON POLICY
More informationFINANCE (No 4) BILL BRIEFING CONTROLLED FOREIGN COMPANIES - CLAUSE 180 AND SCHEDULE 20
TAXREP 31/12 (ICAEW REP 107/12) ICAEW TAX REPRESENTATION FINANCE (No 4) BILL 2012 - BRIEFING CONTROLLED FOREIGN COMPANIES - CLAUSE 180 AND SCHEDULE 20 Briefing submitted in June 2012 by ICAEW Tax Faculty
More informationICAEW is pleased to respond to your request for comments on CR 01/13 Financial Benchmarks.
Our ref: ICAEW Rep 26/13 Your ref: CR 01/13 Mr Alp Eroglu International Organisation of Securities Commissions (IOSCO) Calle Oquendo 12 28006 Madrid Spain Via email: benchmarksconsultationresponses@iosco.org
More informationICAEW REPRESENTATION 30/15
ICAEW REPRESENTATION 30/15 Nullification of Ban on Invoice Assignment Clauses ICAEW welcomes the opportunity to comment on the consultation paper Nullification of Ban on Invoice Assignment Clauses published
More informationSIMPLIFICATION REVIEW: THE ASSOCIATED COMPANY RULES AS THEY APPLY TO THE SMALL COMPANIES RATE OF CORPORATION TAX
SIMPLIFICATION REVIEW: THE ASSOCIATED COMPANY RULES AS THEY APPLY TO THE SMALL COMPANIES RATE OF CORPORATION TAX Memorandum submitted on 22 January 2010 by the Tax Faculty of the Institute of Chartered
More informationICAEW REPRESENTATION 103/17
ICAEW REPRESENTATION 103/17 ASSET SALES IN COMPETITION WITH AN OFFER AND OTHER MATTERS ICAEW welcomes the opportunity to comment on PCP 2017/1 Asset sales in competition with an offer and other matters,
More informationICAEW REPRESENTATION132/17 TAX REPRESENTATION
ICAEW REPRESENTATION132/17 TAX REPRESENTATION LARGE BUSINES COMPLIANCE ENHANCING OUR RISK ASSESSMENT APPROACH ICAEW welcomes the opportunity to comment on the consultation document Large Business compliance
More informationFINANCE (No 4) BILL BRIEFING VAT - NON-ESTABLISHED TAXABLE PERSONS - CLAUSE 201 AND SCHEDULE 27 AND FACE VALUE VOUCHERS - NEW CLAUSE
TAXREP 32/12 (ICAEW REP 108/12) ICAEW TAX REPRESENTATION FINANCE (No 4) BILL 2012 - BRIEFING VAT - NON-ESTABLISHED TAXABLE PERSONS - CLAUSE 201 AND SCHEDULE 27 AND FACE VALUE VOUCHERS - NEW CLAUSE Briefing
More informationTAXREP 34/15 (ICAEW REPRESENTATION 92/15)
TAXREP 34/15 (ICAEW REPRESENTATION 92/15) PREVENT TREATY ABUSE: OECD PUBLIC DISCUSSION DRAFT ICAEW welcomes the opportunity to comment on the public discussion draft Prevent Treaty Abuse published by OECD
More informationIPMA RESPONSE TO LIST OF QUESTIONS. CP 04/16- The Listing Review and implementation of the Prospectus Directive
PART 1 IPMA RESPONSE TO LIST OF QUESTIONS CP 04/16- The Listing Review and implementation of the Prospectus Directive Q2: Do you agree with the proposal that issuers should publish prospectuses on their
More informationTAXREP 38/14 (ICAEW REPRESENTATION 95/14)
TAXREP 38/14 (ICAEW REPRESENTATION 95/14) PAYE CODE NUMBERS HMRC S OBLIGATION TO NOTIFY EMPLOYEES ICAEW welcomes the opportunity to comment on the draft secondary legislation The Income Tax (Pay As You
More informationICAEW TAX REPRESENTATION 68/17
ICAEW TAX REPRESENTATION 68/17 Making Tax Digital: sanctions for late submission and late payment ICAEW welcomes the opportunity to comment on the Making Tax Digital: sanctions for late submission and
More informationICAEW REPRESENTATION 36/15
ICAEW REPRESENTATION 36/15 SEPARATE BUSINESS RULE ICAEW welcomes the opportunity to comment on the Consultation paper, Separate Business Rule, published by the Solicitors Regulation Authority (SRA) on
More informationAssess record for 'Country-by-Country Reporting by Multinational Companies'
Page 1 of 6 Assess record for 'Country-by-Country Reporting by Multinational Companies' Meta Informations Creation date 22-12-2010 Last update date User name null Case Number 462764203322235610 Invitation
More informationTECHNICAL RELEASE. Guidance ACCOUNTING IMPLICATIONS OF CHANGES TO THE FINANCIAL SERVICES AUTHORITY S RULES FOR CALCULATING TECHNICAL PROVISIONS
TECHNICAL RELEASE Guidance ACCOUNTING IMPLICATIONS OF CHANGES TO THE FINANCIAL SERVICES AUTHORITY S RULES FOR CALCULATING TECHNICAL PROVISIONS FSF 02/07 ACCOUNTING IMPLICATIONS OF CHANGES TO THE FINANCIAL
More information17 October Our ref: ICAEW Rep 120/08. Your ref:
17 October 2008 Our ref: ICAEW Rep 120/08 Your ref: Louise Robinson Pensions Administration and Governance Practice The Pensions Regulator Napier House Trafalgar Place Brighton BN1 4DW By email to: rkcondoc@thepensionsregulator.gsi.gov.uk
More informationExposure Draft ED 2015/6 Clarifications to IFRS 15
Hans Hoogervorst Chairman International Accounting Standards Board 30 Cannon Street London United Kingdom EC4M 6XH Deloitte Touche Tohmatsu Limited 2 New Street Square London EC4A 3BZ United Kingdom Tel:
More informationslaughter and may FSA Consultation Paper CP12/25: Enhancing the effectiveness of the UK Listing Regime
slaughter and may FSA Consultation Paper CP12/25: Enhancing the effectiveness of the UK Listing Regime BRIEFING october 2012 INTRODUCTION On 2 October 2012, the FSA published Consultation Paper CP12/25,
More informationHMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on UK Immovable Properties
James Konya NRCG Consultation HM Revenue & Customs Room 3C/04 100 Parliament Street London SW1A 2BQ 15 February 2018 Dear James HMRC and HMT Consultation Document: Taxing Gains Made by Non-Residents on
More informationMAKING TAX DIGITAL: INTEREST HARMONISATION AND SANCTIONS FOR LATE PAYMENT
ICAEW REPRESENTATION 29/18 MAKING TAX DIGITAL: INTEREST HARMONISATION AND ICAEW welcomes the opportunity to comment on the Making Tax Digital: interest harmonisation and sanctions for late payment consultation
More informationTAXREP 11/15 (ICAEW REPRESENTATION 28/15)
TAXREP 11/15 (ICAEW REPRESENTATION 28/15) PAID AND REIMBURSED EMPLOYEE EXPENSES DRAFT FINANCE BILL CLAUSES ICAEW welcomes the opportunity to comment on the draft Finance Bill 2015 legislation Administration
More informationContents Paragraph Introduction 1-3. Who we are 4-6. Key point summary Major points 17-36
TAXREP 28/13 (ICAEW REP 66/13) ICAEW TAX REPRESENTATION OECD INTERNATIONAL VAT/GST GUIDELINES Comments submitted on 2 May 2013 by ICAEW Tax Faculty in response to the OECD consultation document OECD International
More informationTailoring funds regulation following Brexit Consumer, political and regulatory opportunities in the funds sector
Consumer, political and regulatory opportunities in the funds sector www.theaic.co.uk The debate on the future of financial services regulation has focussed on the terms of access to the European Union
More information12 April Our ref: ICAEW Rep 50/12
12 April 2012 Our ref: ICAEW Rep 50/12 Steve Webb MP Minister of State for Pensions Department for Work & Pensions Caxton House Tothill Street London SW1H 9DA Dear Steve Equality Act 2010 and Guaranteed
More information1. Euronext. 2. General Comments
Euronext s Response to the ESMA Consultation Paper entitled Draft Regulatory Technical Standards on prospectus related issues under the Omnibus II Directive 1. Euronext Euronext is a leading operator of
More informationREVIEW OF DOUBLE TAXATION TREATIES AND DOUBLE CONTRIBUTION AGREEMENTS
ICAEW TAX FACULTY REPRESENTATION REVIEW OF DOUBLE TAXATION TREATIES AND DOUBLE CONTRIBUTION AGREEMENTS 2011-12 Memorandum submitted in January 2011 by the Tax Faculty of the Institute of Chartered Accountants
More informationICAEW REPRESENTATION 108/16 TAX REPRESENTATION
ICAEW REPRESENTATION 108/16 TAX REPRESENTATION STRENGTHENING THE TAX AVOIDANCE DISCLOSURE REGIMES FOR INDIRECT TAXES ICAEW welcomes the opportunity to comment on the consultation document Strengthening
More informationFinancial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS. 26 January 2018
Financial Conduct Authority 25 The North Colonnade Canary Wharf London E14 5HS 26 January 2018 (Uploaded at the Financial Conduct Authority s website) Dear Sir/Madam, Standard Chartered s Response to the
More informationIntroduction 1 5. Who we are 6 8. General Comments Further contact 32. Ten Tenets for a Better Tax System Appendix 1
TAXREP 7/12 ICAEW TAX REPRESENTATION PATENT BOX: CORPORATION TAX REFORM Comments submitted on 10 February 2012 by ICAEW Tax Faculty in response to the publication on 6 December 2011 of draft clauses Profits
More informationICAEW REPRESENTATION 40/16
ICAEW REPRESENTATION 40/16 Consultation Paper Recognition and Measurement of Social Benefits ICAEW welcomes the opportunity to comment on the Recognition and Measurement of Social Benefits consultation
More informationRobert Hodgkinson Project Director, Audit Firm Governance Working Group ICAEW Chartered Accountants' Hall PO Box 433 Moorgate Place London EC2P 2BJ
Our Ref NJJ/SAM/FIRM GOVERNANCE Your Ref AUDIT FIRM GOVERNANCE Robert Hodgkinson Project Director, Audit Firm Governance Working Group ICAEW Chartered Accountants' Hall PO Box 433 Moorgate Place London
More informationTREASURY SELECT COMMITTEE VAT INQUIRY Issued 29 June 2018
ICAEW REPRESENTATION 74/18 TREASURY SELECT COMMITTEE VAT INQUIRY Issued 29 June 2018 ICAEW (Institute of Chartered Accountants in England & Wales) welcomes the opportunity to respond to the VAT Inquiry
More informationTAXREP 56/14 (ICAEW REPRESENTATION 136/14)
TAXREP 56/14 (ICAEW REPRESENTATION 136/14) STRENGTHENING THE TAX AVOIDANCE DISCLOSURE REGIMES ICAEW welcomes the opportunity to comment on the consultation document Strengthening the tax avoidance disclosure
More informationIMPROVING THE QUALITY OF PENSION TRANSFER ADVICE
L ICAEW REPRESENTATION 57/18 IMPROVING THE QUALITY OF PENSION TRANSFER ADVICE ICAEW welcomes the opportunity to comment on Improving the quality of pension transfer advice published by the FCA, a copy
More informationImplementation of International Tax Compliance (United States of America) Regulations 2013
TAXREP 25/13 (ICAEW REP 38/13) ICAEW TAX REPRESENTATION Implementation of International Tax Compliance (United States of America) Regulations 2013 Comments submitted on 27 February 2013 by ICAEW Tax Faculty
More informationICAEW welcomes the opportunity to comment on the VAT and Vouchers consultation document published by HMRC on 1 December 2017.
ICAEW REPRESENTATION 24/18 VAT AND VOUCHERS 21 February ICAEW welcomes the opportunity to comment on the VAT and Vouchers consultation document published by HMRC on 1 December 2017. This response of 21
More informationDiscussion Paper 06/3. Financial Services Authority. Implementing MiFID s best execution requirements
Discussion Paper 06/3 Financial Services Authority Implementing MiFID s best execution requirements May 2006 Contents 1 Overview 3 2 Execution policies and arrangements 10 3 Dealer markets 21 4 Review
More informationICAEW REPRESENTATION 94/16 TAX REPRESENTATION
ICAEW REPRESENTATION 94/16 TAX REPRESENTATION Finance Bill (No 2) 2016 Clause 117: SDLT:higher rates for additional dwellings etc ICAEW welcomes the opportunity to comment on the Finance Bill published
More informationREVIEW OF DOUBLE TAXATION TREATIES AND DOUBLE CONTRIBUTION AGREEMENTS
REVIEW OF DOUBLE TAXATION TREATIES AND DOUBLE CONTRIBUTION AGREEMENTS 2010-11 Memorandum submitted on 1 February 2010 by the Tax Faculty of the Institute of Chartered Accountants in England and Wales to
More informationTAXREP 12/15 (ICAEW REPRESENTATION 29/15)
TAXREP 12/15 (ICAEW REPRESENTATION 29/15) FINANCE BILL 2015 DRAFT CLAUSES DIVERTED PROFITS TAX ICAEW welcomes the opportunity to comment on the draft clauses on Diverted Profits Tax published for consultation
More informationMEETING THE OBLIGATIONS TO FILE RETURNS AND PAY TAX ON TIME
MEETING THE OBLIGATIONS TO FILE RETURNS AND PAY TAX ON TIME DRAFT LEGISLATION AND COMMENTARY Memorandum submitted on 3 March 2010 by the Tax Faculty of the Institute of Chartered Accountants in England
More informationConsultation on the review of the Prospectus Directive. Submission from the Association of Investment Companies
Consultation on the review of the Prospectus Directive Submission from the Association of Investment Companies The Association of Investment Companies (AIC) welcomes the opportunity to respond to the European
More informationICAEW TAX REPRESENTATION 128/17
ICAEW TAX REPRESENTATION 128/17 MAKING TAX DIGITAL FOR VAT: LEGISLATION OVERVIEW ICAEW welcomes the opportunity to comment on the Making Tax Digital for VAT: legislation overview published by HMRC on 13
More informationDISCUSSION PAPER FINANCIAL STABILITY AND DEPOSITOR PROTECTION: STRENGTHENING THE FRAMEWORK JANUARY 2008
17 April 2008 Our ref: ICAEW Rep 53/08 Financial Services Authority 25 The North Colonnade Canary Wharf London E14 5HS By email: banking.reform@hm-treasury.gov.uk Dear Sirs DISCUSSION PAPER FINANCIAL STABILITY
More informationThe New EU Prospectus Regulation An equity capital markets perspective
The New EU Prospectus Regulation An equity capital markets perspective On 30 November 2015, the European Commission published its proposals for a new prospectus regulation to reform the European prospectus
More informationContents Paragraphs Introduction. 1 4 Key point summary Detailed comments on the draft legislation
TAXREP 16/15 (ICAEW REPRESENTATION 35/15) DRAFT FINANCE BILL 2015 CLAUSES: ENFORCEMENT BY DEDUCTION FROM ACCOUNTS ICAEW welcomes the opportunity to comment on the draft legislation and the Tax Information
More informationThe Association of Corporate Treasurers Interest Representative Register ID:
The Association of Corporate Treasurers Interest Representative Register ID: 64617562334-37 Comments in response to Review of the markets in Financial Instruments Directive (MiFID) The European Commission
More informationTAXREP 49/13 (ICAEWREP 132/13)
TAXREP 49/13 (ICAEWREP 132/13) ICAEW TAX REPRESENTATION SUPPORTING THE EMPLOYEE-OWNERSHIP SECTOR Comments submitted in September 2013 by the Tax Faculty of the Institute of Chartered Accountants in England
More informationTechnical Rules: Exposure Draft and Interim Guidance for the Performance of Assurance Work on Benchmarks and Indices
09 April 2013 ICAEW Attn: Philippa Kelly Technical Strategy PO Box 433 Chartered Accountants Hall Moorgate Place London EC2P 2BJ Submitted to philippa.kelly@icaew.com Re: Technical Rules: Exposure Draft
More informationH M Treasury: Business Rates Review
H M Treasury: Business Rates Review Submission from the Chief Economic Development Officers Society (CEDOS) and the Association of Directors of Environment, Economy, Planning & Transport (ADEPT) May 2015
More informationThe distinct nature of insurance business and the introduction of a specific insurance objective;
Financial Regulation Strategy HM Treasury 1 Horse Guards Road London SW1A 2HQ Via Email: financial.reform@hmtreasury.gsi.gov.uk 8 September 2011 Dear Sirs A new approach to financial regulation: the blueprint
More information