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Q4 Commercial Forecast 2016 News - Briefing

Date: 11/10/2016 Authors : David Fletcher

Welcome to the autumn edition of our Commercial Forecast . Our forecasts help businesses to stay in the know about current and future legal developments which might affect them and the markets in which they operate.   The range of topics covered in this edition is typically broad, ranging from th...

News at last: the extension of IHT to UK residential property held in non-UK structures News - Briefing

Date: 22/08/2016 Authors : Debbie Pennington

It was announced in the Summer Budget 2015 that, from April 6 2017, inheritance tax (IHT) would be extended to offshore structures holding UK residential property that to date have escaped IHT entirely. On 19 August, a further consultation paper was published giving fuller details on the proposed...

Non-dom changes News - Briefing

Date: 22/08/2016 Authors : Nick Dunnell

At last, the long wait is over… but not quite. The government published a further consultation document (' con doc' ) on 19 August relating to the proposed changes to the taxation of non-doms. The con doc poses a number of specific questions but also provides a bit more detail on the future...

Tax tips for property transactions News - Briefing

Date: 28/07/2016 Authors : James Bromley

Many charities' properties are their most valuable and important asset. As well as being financially valuable, a charity's property is often central in enabling core charitable activities to be carried out. The inherent value of property means that any property-related tax charge can have a...

Q3 Commercial Forecast 2016: Brexit Edition News - Briefing

Date: 30/06/2016 Authors : David Fletcher

Welcome to the Summer edition of our Commercial Forecast . Our forecasts help our business clients stay in the know about legal developments that might affect them and the markets in which they operate. For this edition we have focused on the outcome of the Brexit referendum and some of the legal...

Stamp Duty Land Tax Additional Rates News - Briefing

Date: 06/05/2016 Authors : James Bromley

At the Autumn Statement in November 2015, a series of new additional SDLT rates were announced, effective from 1 April 2016. We have previously published two Q&A briefings outlining the scope of the new rates (available here and here ).

Company Residence and Management and Control: How to Navigate the Pitfalls How we help - News

Date: 26/04/2016 Authors : Robert Field

The cases of Laerstate BV v HM Revenue & Customs and Wood v Holden (2006)  serve as a useful reminder of all the things one must and must not do in order to ensure that a company doesn't become resident in the UK by reason of its management and control. We present the facts of the cases and advis...

Proposed changes to deductibility of interest may hit property industry News - Briefing

Date: 13/04/2016 Authors : Robert Field

Base erosion and profit shifting (BEPS) refers to techniques used by some multinational group companies to engineer where profit and expenditure arise in order to reduce their tax bill. To tackle this, the BEPS Project was formed. The Project identified the use of loans to generate interest...

Following the golden rule News - Briefing

Date: 17/03/2016 Authors : Adam Carvalho TEP, Richard McDermott

This article was first published by Solicitors Journal on 15 March 2016, and is reproduced by kind permission.  Adam Carvalho and Richard McDermott discuss recent cases on the duties of executors and the concept of testamentary capacity. Please click here to read the article in full. 

Drawing the strands together (again) – a guide to the new UK property tax regime News - Briefing

Date: 28/01/2016 Authors : Nick Dunnell, Russell Cohen, Holly Jones

Over the past 4 years the UK government has: introduced new taxes on high value residential property held by companies; significantly increased certain taxes on UK residential property;  andintroduced an extension of capital gains tax (CGT) to non-residents disposing of residential property.

Inn the Field of Play - January 2016: IAAF - Withholding tax and exemptions for athletes News - Briefing

Date: 27/01/2016 Authors : Udo Onwere

In this week's extensive look at the IAAF, world athletics' governing body, we consider whether events such as the IAAF World Championships will follow previous tournaments and enact specific tax legislation to encourage attendance from the world's elite athletes. The 16 th World Championship eve...

Stamp Duty Land Tax Changes Q&A Part 2 News - Briefing

Date: 04/01/2016 Authors : James Bromley

On 4 December 2015, we published a Q&A outlining the basics on the new higher rates of SDLT announced by the government in its Autumn Statement.

Carried interest taxation: the impact of the draft Finance Bill 2016 News - Briefing

Date: 18/12/2015 Authors : Robert Field, Simon Ward

The 2016 Draft Finance Bill has shown that the government will be looking to implement a more radical change to how carried interest will be taxed than first anticipated.

Stamp Duty Land Tax Changes Q&A Part 1 News - Briefing

Date: 03/12/2015 Authors : James Bromley

At the Autumn Statement on 25 November 2015, the Chancellor of the Exchequer announced that higher rates of stamp duty land tax (SDLT) would apply to purchases of “additional residential properties” from 1 April 2016.

Charitable Grants and VAT News - Briefing

Date: 19/10/2015 Authors : Charlotte Black

This article was first published in the 16 October 2015 issue of the Tax Journal, reproduced here with kind permission of the editor. Charities can find themselves in a tough spot when it comes to the application of the VAT regime to voluntary funding arrangements. As a grant recipient, a charity...

Educational institutions paying investment manager fees may be in line to recover associated VAT News - Briefing

Date: 03/08/2015 Authors : Charlotte Black

Cambridge University has recently won confirmation that it can treat the fees of its investment fund managers as part of the university's general costs ("overheads") enabling a partial recovery of the VAT charged on those fees. The issue was first considered in 2013 by the First Tier Tribunal of...

Summer Budget 2015: Inheritance Tax – Residence Nil Rate Band and Existing Nil Rate Band News - Briefing

Date: 10/07/2015 Authors : Diana Davidson, Catherine McAleavey

The Existing Nil Rate Band At present inheritance tax is payable at a rate of 40% on the taxable value of a deceased person's net assets (an "estate") where that value, including the value of any taxable lifetime gifts, exceeds £325,000.  The range of values from £0 - £325,000 is generally known ...

Summer Budget 2015: what non-doms need to know News - Briefing

Date: 08/07/2015 Authors : Russell Cohen, Nick Dunnell, Holly Jones

For non-UK domiciled clients, there are two key sets of changes. The first relates to the availability of the remittance basis and the second to the inheritance tax (IHT) treatment of UK residential property. We deal with each in turn.

Drawing the strands together - a guide to the new UK property tax regime News - Briefing

Date: 15/06/2015 Authors : Nick Dunnell, Holly Jones

Over the past three 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 introduced an extension of capital gains tax ( CGT ) to non-residents disposing o...

Non-UK residents: Capital gains tax reporting News - Briefing

Date: 27/05/2015 Authors : 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 disposa...

The new UK government: what is the future for non-doms? News - Briefing

Date: 12/05/2015 Authors : Russell Cohen, 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. Th...

Q1 Commercial Forecast News - Briefing

Date: 14/01/2015 Authors : 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. Please click here to read

Capital gains tax – the net closes in News - Briefing

Date: 28/11/2014 Authors : Nick Dunnell, 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 draf...