In the Autumn Budget, the Chancellor announced that legislation will be included in the Finance Bill 2017/18 (the “Finance Bill”) giving effect to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Instrument”). The Multilateral Instrument can be accessed here. The Multilateral Instrument implements aspects of … Continue reading Finance Bill 2017/18: the BEPS Multilateral Instrument

In addition to the changes to EIS, SEIS and VCT set out in our blog, further changes were announced in today’s Budget that will only apply to VCTs. The Government has acknowledged in its response to the “Financing growth in innovative firms” consultation that VCTs have begun to move away from investing in established companies … Continue reading VCT – high-risk, high-reward?

Clampdown on so-called capital preservation As was widely expected, the Government intends to change the EIS, SEIS and VCT rules to ensure they are focussed on high-risk, “genuine entrepreneurial” IP-intensive companies and are not used in a way that provides “capital preservation” for investors.   Whilst the good news is that no one industry has been … Continue reading A mixed bag of news for the EIS industry

By way of “marking my own homework”, I have revisited my Budget predictions post to see how many I got right.  Updates in bold type and words in colour are live links to blog posts or documents. Overall not a bad effort if I may say so myself.   • extension of corporation tax to … Continue reading Today’s Budget: Were our predictions right?

  The Government has confirmed that it will legislate in relation to the taxation treatment of partnerships. The proposed changes were originally published on 13th September and they mostly relate to administrative aspects. However, the original proposals also included changes in relation to profit allocation rules. These changes are designed to address HMRC concerns that … Continue reading Partnership taxation

HM Treasury has published a position paper in respect of taxing the digital economy (available here) following the Chancellor’s Autumn Budget. The paper proposes that multinational groups’ profits should be taxed where value is generated. For example, a social media business generates value through users worldwide, but is only taxed where it is tax resident … Continue reading Taxing the Digital Economy: first steps by the UK

There was good news today for those that feared that the Government might use the Budget to announce proposals to reverse all the tax advantages of personal service companies. The Government is merely to consult on the tax treatment of workers using service companies to provide services to the private sector. The tax savings which come … Continue reading Workers using service companies and in the gig economy – further consultations

The Chancellor has today announced that hoped-for changes will be made to the decommissioning tax relief regime, taking effect from 1 November 2018. The proposed changes will be a world first for a tax regime, and are intended to encourage investment in late-life assets in the North Sea. A review on the topic had been … Continue reading Oil and Gas in Budget 2017: Transferable Tax History

Whilst not mentioned in the Chancellor’s statement, the Budget documents reveal the Government’s intention to bring offshore residents within the scope of UK tax on gains on commercial property from April 2019.  UK tax will also be extended to indirect disposals of both commercial and residential property, and the existing exemption from the charge on … Continue reading Non-residents to be taxed on commercial property gains

Participants in Sharesave (or SAYE) plans who are on parental leave will from April 2018 be able to miss up to twelve months savings as opposed to just six months savings, which is the current position. Employees save monthly over a three or five year period before they can exercise their option and receive shares. … Continue reading Sharesave plans – good news for those on parental leave

Analysis from the award-winning CMS Tax Group