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: The Finance Act 2012 Rules
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...
The Prudential decision on privilege
Date Posted: 23/01/2013
Author: James Price and Kate Allass
The UK Supreme Court has today handed down its judgment in the case of R (on the application of Prudential plc and another) -v- Special Commissioner of Income Tax and another  UKSC1.
Taxation of high value residential properties - draft legislation published
Date Posted: 11/12/2012
Author: Alison Parker
Earlier today, the Government published draft legislation and a summary of proposals in respect of the changes to the taxation of residential properties worth over £2 million held by certain ‘non-natural persons’. These changes come into effect in April 2013.
John Lewis economy? Old News Nick
Date Posted: 05/09/2012
Author: Richard Belsey
Following the statement from Nick Clegg earlier this year that employees should be given the right to own shares in the company that employs them, this article looks at the uses and advantages of employee share schemes and briefly outlines some of the key features of two of the more popular tax-favoured employee share schemes; the enterprise management initiatives (E...
Leavers, Arrivers and Day Trippers - the Statutory Residence Test for internationally mobile individuals
Date Posted: 03/08/2012
Author: Alexandra Hollingshead
Benjamin Franklin might have thought of tax as one of life’s certainties, and yet the concept of tax residence for UK purposes has long been both uncertain and unclear. In recognition of this, the Government has proposed that tax residence should be assessed according to new legislation – the Statutory Residence Test, or ‘SRT’. This test will come into forc...
Tax reputation for high-profile individuals and corporations - being 'legal' is not enough
Date Posted: 13/07/2012
Author: Julian Pike
It is sometimes suggested that there is a clear dividing line between legal tax avoidance and criminal tax evasion, and anything goes so long as it is on the right side of the line. As a number of high-profile individuals and companies have found out to their cost in recent months, however, the reality is not so simple.
The "Patent Box" – putting the UK on the map
Date Posted: 28/05/2012
Author: Peter Wienand
The Patent Box tax regime, contained in the Finance Bill 2012, is part of the Government’s broader aim to make the UK’s tax system more competitive and appealing as a place of business innovation and growth. The regime applies a 10% corporation tax rate to profits attributed to patents by 2017.
The reduction in corporation tax will occur in stages. In April 2013...
Enterprise Management Incentive Scheme
Date Posted: 23/04/2012
Author: Robert Field
The Enterprise Management Incentive Scheme (EMI) was introduced in 2000 and continues to provide a popular tax advantaged share option for employees. This note summarises the EMI framework, looking at its advantages to both company and employee, the conditions that must be satisfied to fulfil the various eligibility criteria and the procedural steps that must be followed w...
Budget 2012: Wealth taxes by the back door?
Date Posted: 23/03/2012
Author: Debbie Pennington
It has been called the Millionaire's Budget due to a headline grabbing reduction in the top rate of income tax from 50% to 45% (from 6 April 2013). As widely predicted, however, it is not all good news for wealthy international clients, especially in relation to tax on UK properties. This briefing looks at SDLT and CGT on UK properties, anti-avoidance provisions ...
A private client tax update
Date Posted: 07/02/2012
Author: James Carleton
This article gives a summary of the Golding case in regard to agricultural property relief and updates on tax reductions for lifetime gifts of pre-eminent objects to the Nation and charitable gifts on death and the impact on inheritance tax.
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