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Briefings

We produce regular briefings which examine the latest legal developments, regulations and case law. 

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...

Budget 2014: Measures affecting private clients

Date Posted: 28/03/2014 Author: Robert Field

This article appeared in the Tax Journal 28 March 2014, reproduced here with the kind permission of the editor.

The Commissioners for H M Revenue & Customs (Respondents) v Forde and McHugh Limited (Appellant) ([2014] UKSC 14)

Date Posted: 26/02/2014 Author: Robert Field and Elizabeth Sainsbury

The Revenue has long tried to argue that arrangements deferring the payment of remuneration to an employee should be ignored.  The reason is simple – if the fact that the employee does not yet have the money can be ignored, the tax is paid earlier.

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

Introduction

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 [2013] 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.

High value residential property Consultation published: What clients should do (or not do) now…

Date Posted: 08/06/2012 Author: Helen Reid

Two of the major changes announced in the UK Government's 2012 Budget were a proposed annual charge (sometimes referred to as a mansion tax) and, for the first time in the history of UK Capital Gains Tax (CGT), the extension of the current CGT regime to include certain non-UK residents.

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...

Tax breaks for Enterprise Zones – do they go far enough?

Date Posted: 04/04/2012 Author: Helen Reid

Helen Reid looks at the tax benefits of Enterprise Zones introduced as part of the Government's plans to get Britain building again...

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.  

HMRC's updated guidance on heritage property

Date Posted: 10/01/2012 Author: Lucie Pfaff

HMRC recently published a revised version of Capital Taxation and the National Heritage (CTNH) - known in its last published edition (in 1986) as IR67. Lucie Pfaff looks at the approach HMRC adopts in administering the legislation on capital taxation reliefs for heritage property.

The UK/Swiss Tax Cooperation Agreement: A Closer Look

Date Posted: 04/11/2011 Author: Robert Field

Since the publication of the UK/Swiss Tax Cooperation Agreement, many of the discussions amongst professionals have centred on what the Agreement may mean for clients and to what extent the new landscape of disclosure may change clients' views of Swiss banking.

In this briefing, Robert Field, Head of Tax at Farrer & Co, and Helen Reid, Solicitor in our Tax team, ...

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