The World Intellectual Property Organization has recently suggested that one third of the value of the products that consumers buy is derived from intangibles such as technology and branding. With the growing importance and value of intangibles in mind, coupled with the government’s suggestion that technology will be one of the key drivers for the … Continue reading Budget 2018: Reform of the UK corporation tax intangibles regime

On 29 October 2018, Phillip Hammond, the Chancellor of the Exchequer, announced in his Budget that the UK will be pressing ahead with a unilateral Digital Services Tax (“DST”) from April 2020, subject to an appropriate international measure being in place. The DST will be chargeable at a rate of 2% on those revenues of … Continue reading New UK Digital Services Tax

The Finance Bill 2018-19 will introduce UK tax currently at 20% on income from intangible property held in low-tax jurisdictions to the extent that the income is referable to UK sales. This measure will come into effect from 6 April 2019. The UK tax will be levied on relevant gross income realised by non-UK resident … Continue reading UK Tax on Offshore Intangibles

The Chancellor has announced a number of changes in respect of the right to claim Entrepreneurs’ Relief (ER) in yesterday’s Budget. For disposals on or after 6 April 2019, the minimum period throughout which the qualifying conditions for ER must be met will be extended from 12 months to 24 months. Furthermore, in addition to … Continue reading Budget 2018: Entrepreneurs’ Relief – holding period for disposal of “relevant EMI shares”

In yesterday’s Budget, the Chancellor introduced a number of changes to Entrepreneurs’ Relief which may have immediate, significant and expensive implications for anyone who is hoping to qualify for the relief. The most significant change is the addition of a 5% economic ownership test but the requisite ownership period was also doubled from 12 months … Continue reading Budget 2018: Changes to Entrepreneurs’ Relief

In his Budget speech on 29 October the Chancellor of the Exchequer, Philip Hammond, announced significant changes to the UK’s capital allowance regime.  Briefly, these changes were: The introduction of a new Structures and Buildings Allowance giving tax relief for the cost of non-residential structures and buildings; The reduction of the “special” rate of capital … Continue reading Budget 2018 – Capital Allowances

The Corporate Interest Restriction (“CIR”) rules, which came into force on 1 April 2017, limit the net financing costs which a group can deduct against its UK taxable income. The rules apply to interest and amounts economically equivalent to interest, which are referred to as “tax-interest” in the legislation. Tax-interest includes the financing costs of … Continue reading Corporate Interest Restriction Rules & IFRS 16 Leases

The International Accounting Standards Board’s new international accounting standard on leases, IFRS 16 Leases (“IFRS 16”), will shortly be coming into force in respect of periods of account beginning on or after 1 January 2019. For lessees, the new standard has important implications, bringing most leases on-balance sheet, while eliminating the dichotomy between finance leases … Continue reading UK Tax Changes in Response to New Lease Accounting Standard (IFRS 16 Leases)

Today we had the Chancellor’s first Spring Statement since the decision to move the Budget to the Autumn. The Chancellor took pains to manage expectations downwards but, while there were no major tax announcements for the new financial year, there were some interesting consultations launched and updates on earlier consultations. Entrepreneurs’ Relief (ER) ER provides … Continue reading The Spring Statement: What’s new?

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

Analysis from the award-winning CMS Tax Group