The Chancellor has confirmed that certain previously announced corporation tax measures will be going ahead.  Additionally, he also announced a consultation on bringing non-UK resident companies with UK income (e.g. offshore companies carrying on a property business in the UK), which are currently subject to income tax on such income, within the scope of corporation … Continue reading CORPORATION TAX CHANGES – UPDATE

Today’s Autumn Statement confirms that the sweeping changes to the taxation of non-UK domiciliaries (“non-doms”) which are due to take effect in April 2017 remain on track. Further details and legislation on these proposals will be released on 5 December. Individuals will then have just a few months to plan and execute any restructuring which … Continue reading Non-doms

The Finance Bill will include sanctions for enablers of tax avoidance. If the August 2016 consultation is a guide then this refers not merely to those who design, promote and market avoidance – but everyone in the supply chain who benefits from an end user implementing avoidance arrangements and without whom such arrangements could not … Continue reading Penalties for tax avoidance enablers

The ability to offer tax-favoured employee shareholder shares or ESS, until recently very common in private equity company arrangements, has been withdrawn with almost immediate effect. The only ESS arrangements that can now be completed are those where the independent advice has been given in which case the relevant employee shareholder agreement must be entered … Continue reading No more ESS arrangements possible

Today’s Autumn Statement included no mention of rates of gambling duty being raised, which is good news. Also not mentioned was any move by the Government to change the VAT rules, such that “business to business” supplies of advertising would be treated as supplied where “used and enjoyed”.  This is the concern that advertising supplies … Continue reading Gambling taxes

There were very limited property specific tax measures introduced in the Autumn Statement.  However, wider changes around interest deductibility, losses, the taxation of non-residents and the substantial shareholding exemption will have a major effect on the industry. Interest expenses As expected the government will limit interest deductions from April next year.  The proposals broadly follow the OECD recommendations with a … Continue reading Property briefing

Last year’s Budget saw the ‘effective abolition’ of petroleum revenue tax (‘PRT’), which had previously applied to certain oil and gas fields on the UK continental shelf. Rather than abolishing the tax entirely, the PRT rate was reduced to zero per cent, largely in order to ensure that participants were still able to carry back … Continue reading Simplifying the administration of PRT

Background Following a consultation process in 2015, the Government announced at Budget 2016 that it would make changes to the taxation of termination payments. The Office of Tax Simplification (OTS) had previously highlighted the complexity of the existing rules in its report in 2014 and recommended that they be simplified. On 10 August 2016, HMRC … Continue reading The new regime for termination payments

As announced at Budget 2016 and following consultation, the Government will introduce legislation in Finance Bill 2017 and secondary legislation to clarify the rules on capital allowances, chargeable gains and investments by co-ownership Authorised Contractual Schemes in offshore funds, as well as information requirements on the operators of these schemes.  Clarity through legislation will be welcome, … Continue reading Authorised Contractual Schemes: more clarity

From April 2017, new benefits in kind provided as part of salary sacrifice arrangements will be subject to income tax and NICs as if they were paid as salary, thus removing the tax and NICs benefits of many benefit packages. A number of arrangements will not be caught, however, and arrangements already in place will be … Continue reading Salary sacrifice – bad news but at least existing arrangements are protected