All posts by Pat Dugdale

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?

It’s Budget Day and we’re gearing up for what is expected to be one of the most politically charged Budgets in recent years. The CMS Tax Team will be blogging during the day. The Blog is interactive so do let us have your comments. The Chancellor’s announcements may include: • extension of corporation tax to … Continue reading Budget Day: what to look out for

The UK’s Substantial Shareholdings Exemption (“SSE”) will be extended from April 2017. The main beneficiaries will be investment companies selling shareholdings of 10% or more in trading companies and companies owned by institutional investors which are themselves exempt from UK tax on capital gains The SSE was introduced in 2002 to permit trading groups to … Continue reading Substantial Shareholdings Exemption to be extended

The Chancellor will deliver his Autumn Statement later today. The tax team at Olswang will be blogging on key tax developments together with their future colleagues from CMS and Nabarro (our three firms will combine from 1 May 2017). The announcements may include: possible mitigation of George Osborne’s SDLT and interest relief measures targeting buy-to-let landlords; … Continue reading Autumn Statement: what to expect

As a result of conflicting decisions in two recent tax cases, there is uncertainty as to the impact of deferred shares (and other shares with no dividend rights) on shareholder tax reliefs, in particular entrepreneurs’ relief for individuals and group reliefs for corporate shareholders. The issue is whether these shares are “ordinary share capital” for tax … Continue reading Deferred shares: impact on entrepreneurs’ relief and group relief

Further to Graham Chase’s blog on Budget Day on the additional 3% SDLT on second homes and other “additional” residential property, Warren Gordon has written a detailed account of the changes, the recently published guidance and the practical implications and it can be found on our website here. It includes a link to the guidance and to … Continue reading SDLT additional 3% rate: more information now on our website

In our earlier blog we reported on draft legislation  which would tax carried interest and other asset managers’ performance incentives as trading income unless the average holding period of the fund’s assets was at least four years.  HMRC conceded that this was a work in progress and discussions have been conducted with the BVCA and other interested parties … Continue reading Carried interest: new legislation modified

In recent years the Chancellor has had a dual approach to corporation tax, reducing the headline rates, which feature in international comparisons, but increasing the amounts on which tax is charged so tax revenues are not reduced. This has been done not only by  counteracting perceived tax avoidance but also by restricting or delaying permitted deductions such … Continue reading Corporation tax: future rate reduction, but …

Changes to the tax treatment of carried interest (to the detriment of fund managers) are becoming a regular feature of Finance Acts. Yesterday’s draft Finance Bill clauses will continue the trend by implementing last July’s proposals to tax some carried interest and other performance incentives as trading income where the fund does not hold its … Continue reading HMRC v. Carried Interest: Round 3

SDLT From 1 April 2016, a 3% higher rate of SDLT will apply to purchases of “additional residential properties”. This charge is aimed at those buying residential property for buy-to-let or as second homes. The government states that “some” of the additional tax collected will be used to provide £60 million for communities in England … Continue reading Autumn Statement 2015 – Residential property changes