Non-UK residents: Capital gains tax reporting
Date Posted: 27/05/2015
Author: Diana Davidson
From 5 April 2015 disposals of UK residential property by non UK residents may be subject to UK capital gains tax, whether or not within the regime applying to dwellings held via corporates introduced in April 2013, (“ATED related CGT”).
This note highlights key reporting issues affecting disposals of UK real property by non-UK residents.
The new UK government: what is the future for non-doms?
Date Posted: 12/05/2015
Author: Russell Cohen and Nicola Pomfret
On 7 May, the UK elected the government which will be in place for the next five years. The result was clearer than anticipated: the Conservative Party won the election with a narrow majority. The outcome is a first Conservative majority government (i.e. not in coalition) for nearly 20 years. The Labour Party had announced during its campaign that the abolition of the ...
Q1 Commercial Forecast
Date Posted: 14/01/2015
Author: David Fletcher
Welcome to our inaugural Commercial Forecast.
In each edition we flag up key legal developments over the coming financial quarter, helping to put them on the radar of our business clients and their advisors.
Capital gains tax – the net closes in
Date Posted: 28/11/2014
Author: Nick Dunnell and Debbie Pennington
The government released its response to the consultation on extending capital gains tax (CGT) on 27 November 2014 which was quickly followed by the publication of draft legislation on 10 December. Together these deal with many of the potential issues identified during the consultation. The draft legislation is a work in progress and does...
Community amateur sports clubs: HMRC consults on draft qualifying regulations
Date Posted: 21/10/2014
Author: James Maloney
Following the Government's consultation on secondary legislation for Community Amateur Sports Clubs (CASCs) last year, HMRC has launched a technical consultation on the draft regulations on qualifying conditions for CASCs.
The draft regulations provide detail to the new rules governing the CASC scheme, introduced in April 20...
Mixed funds, mixed messages
Date Posted: 06/08/2014
Author: Russell Cohen & Holly Jones
HMRC changes the tax treatment of loans for non-domiciliaries
HMRC has announced a U-turn in its approach to UK resident non-domiciliaries (non-doms) using foreign income and gains as collateral (i.e. security) for loans that are brought into the UK.
Non-doms who have these loans in place wi...
Business investment relief for non-UK domiciliaries
Date Posted: 30/07/2014
Author: Christine Payne Smith
In the past, changes to the remittance rules have, more often than not, limited the scope for a non-UK domiciliary to bring foreign income or gains to the UK without incurring UK tax. Therefore, the introduction in 2012 of a business investment relief for remittance basis users was widely welcomed. This note considers the operation of the relief, as well as some ...
Try, try and try again: What to look out for in the new IHT regime for trusts
Date Posted: 23/07/2014
Author: Debbie Pennington
The Government recently published the third consultation paper on the proposed changes to the inheritance tax (IHT) treatment of trusts. The stated purpose of the consultation is to simplify the IHT treatment of trusts but the real purpose appears to be to put a stop to tax planning using multiple trusts. It is likely that the law has already...
Non-UK residents, residential property and capital gains tax
Date Posted: 07/04/2014
Author: Diana Davidson & Nick Dunnell
Historic liability of non-residents to CGT
Historically, non-residents have not been subject to capital gains tax (CGT) unless carrying on a business in the UK through a branch or agency. There have for many years been anti-avoidance rules that attribute gains to UK residents who are beneficiaries or settlors of non-re...
HMRC Taxation of LLPs: Revised Guidance Issued
Date Posted: 26/02/2014
Author: Jonathan Haley
On 21 February 2014 HMRC issued revised guidance and technical notes relating to the taxation of Salaried Members of LLPs. The new guidance significantly expands on the draft issued in December 2013 and provides helpful clarity in several areas, though no material change to the scope of the legislation.
Capital Gains Tax – casting the net further
Date Posted: 05/02/2014
Author: Nick Dunnell
On 5 December 2013 the Chancellor announced a consultation on the extension of capital gains tax (CGT) to all non-residents on disposals of UK residential property. No details have been provided except that the new provisions will come into effect on 6 April 2015. In the absence of any indication from the Government as to the new regime, how is it likely to apply...
The Isle of Man Disclosure Facility (IOMDF)
Date Posted: 27/02/2013
Author: Robert Field
Following the Liechtenstein Disclosure Facility (LDF) (2009) and the coming into force of the UK/Swiss Agreement (January 2013), the first part of the UK's new tax agreement with the Isle of Man has just been released. Having dealt with continental European tax havens, the Government is clearly setting its sights closer to home.&nb...
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