In March we provided an update on the Government’s announcement in Budget 2016 that it would bring the treatment of “free plays” for remote gaming duty purposes in line with the treatment of “free plays” for general betting duty purposes. Currently the use of “free plays” will not give rise to the receipt of a … Continue reading Consultation on the treatment of “freeplays” in remote gaming duty released

As a result of conflicting decisions in two recent tax cases, there is uncertainty as to the impact of deferred shares (and other shares with no dividend rights) on shareholder tax reliefs, in particular entrepreneurs’ relief for individuals and group reliefs for corporate shareholders. The issue is whether these shares are “ordinary share capital” for tax … Continue reading Deferred shares: impact on entrepreneurs’ relief and group relief

Further to Graham Chase’s blog on Budget Day on the additional 3% SDLT on second homes and other “additional” residential property, Warren Gordon has written a detailed account of the changes, the recently published guidance and the practical implications and it can be found on our website here. It includes a link to the guidance and to … Continue reading SDLT additional 3% rate: more information now on our website

Today’s budget saw the Chancellor tinker around the margins of the pensions system. Having backed down on his widely-rumoured plans to cut tax relief on contributions, the Chancellor instead announced “Lifetime ISAs” which will be launched in April 2017 and which will effectively act as secondary pensions saving accounts which can be opened by anyone … Continue reading Tinkering with Pensions

One of the 15 BEPS action points was the use by multi-national groups of interest and other financing expense as a means of diverting profits.  Following initial consultation the Government has confirmed that it will introduce a new structural fixed ratio rule in line with the OECD’s recommendations.  The key points that have emerged (mostly … Continue reading TAX DEDUCTIBILITY OF CORPORATE INTEREST EXPENSE

Today’s Budget continued the recent trend of announcing changes to the ER regime. However, unlike previous Budgets, today’s changes generally expand the situations in which ER will be available. The main change is the extension of ER to shares held by individuals who are external investors rather than employees or directors. The Budget materials also … Continue reading Entrepreneurs’ relief – not just for entrepreneurs

Reforms announced in the budget today will relax the rules on the use of carried forward losses.  Under the new rules, companies will be able to surrender losses from prior periods by way of group relief and the restrictions on the types of profits against which carried forward losses can be set will be relaxed. … Continue reading New loss carry forward rules for companies

The 2016 Budget proposes that withholding tax will apply to most royalty payments from later this year. Additional measures will apply to prevent avoidance of withholding taxes on royalty payments made to connected persons. The government is  targeting multinational groups which shift profits to low tax jurisdictions to reduce the profits which are subject to UK corporation tax. Wider … Continue reading Withholding tax on royalty payments

Termination payments The Government has announced changes to the way non-contractual termination payments will be taxed from April 2018. The position is complex, but very broadly certain payments which are non-contractual “ex gratia” in nature are tax free up to £30,000 upon termination of employment.  The excess is subject to income tax but is not … Continue reading Employment income – selective aspects

In our earlier blog we reported on draft legislation  which would tax carried interest and other asset managers’ performance incentives as trading income unless the average holding period of the fund’s assets was at least four years.  HMRC conceded that this was a work in progress and discussions have been conducted with the BVCA and other interested parties … Continue reading Carried interest: new legislation modified

Analysis from the award-winning Olswang Tax Group