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

Drawing the strands together – a guide to the new UK property tax regime

Date Posted: 19/02/2015 Author: Nick Dunnell and Russell Cohen and Holly Jones

Over the past 3 years the government has:

  • introduced new taxes on high value residential property held by companies (whether UK or offshore);
  • significantly increased certain taxes on UK residential property; and
  • announced further taxes to come into effect in the future.


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...

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


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...

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