All posts by Stephen Smith, Legal Director, CMS

The 2016 Budget proposes that withholding tax will apply to most royalty payments from later this year. Additional measures will apply to prevent avoidance of withholding taxes on royalty payments made to connected persons. The government is  targeting multinational groups which shift profits to low tax jurisdictions to reduce the profits which are subject to UK corporation tax. Wider … Continue reading Withholding tax on royalty payments

George Osborne’s 2016 Budget contains a surprisingly broad range of new tax measures addressing everything from sporting testimonials to oil fields.  However, the main changes are as follows. Companies Corporation tax will come down to 17% from April 2020. From April 2017, companies will only be able to use carried forward losses against 50% of their profits above … Continue reading Budget 2016 – headline points

The Chancellor’s 2016 Budget devotes very little attention to non-doms.   This alone is something of a relief, given the number of recent changes to these rules. The 2016 Budget confirms that the main changes announced in the Summer Budget 2015 will be introduced in the Finance Bill 2017 and become effective from April 2017 (i.e. deemed … Continue reading Good news for deemed doms

The Chancellor will deliver his 2016 Budget today.  Press coverage suggests that the public finances allow him limited room to manoeuvre. We anticipate the Budget will include: final rules on the additional 3% stamp duty land tax on the purchase of second homes; a clamp down on the use of personal service companies; an update on the UK’s implementation of … Continue reading Budget 2016

The 2015 Autumn Statement is notable for the lack of significant tax measures. The main tax announcements related to residential property (see our separate blog post). A consultation on the company distribution rules will be published later this year. The government will go ahead with changes to tax as income asset managers’ performance incentives unless … Continue reading Autumn Statement 2015

In July 2015, the Chancellor announced his intention to abolish permanent non-dom status for income tax and capital gains tax with effect from April 2017. Details on these proposals, which first slipped out on 21 September in the form of a Consultation Document (“Condoc”), only to be rapidly removed from HM Treasury’s website, are summarised below.  The … Continue reading Non-Dom changes – details slip out

The Chancellor has predictably announced further restrictions on the non-dom rules in today’s 2015 Summer Budget.   The key measures are: non-dom status will only be available for IHT and income tax and capital gains tax for the first 15 years of residence in the UK; some UK-born individuals who move abroad will be prevented from … Continue reading Non-doms: more restrictions

Some of the measures announced this afternoon in the 2015 Summer Budget are as follows: Corporation tax corporation tax to be reduced to 19% in 2017 and 18% in 2020; corporation tax instalment payment dates brought forward for businesses with profits of £20m; annual investment allowance to settle at a permanent level of  £200,000 from … Continue reading Overview of main measures

All bad news In the run up to the general election next Thursday, each of the main political parties has proposed changes to the taxation of UK resident non-domiciliaries (“non-doms”). The statements made in published manifestos and by party leaders during interviews are summarised below.  These provide the best available indication as to what changes are … Continue reading General election – bad news for non-doms

In connection with last week’s Budget, the Government has announced plans to introduce new penalties and offences for tax evasion targeting both evaders and their advisers. In relation to the evasive taxpayers, there is to be a new ‘strict liability’ criminal offence for tax evasion relating to offshore income.  A strict liability offence means that … Continue reading Tax evasion: massive increase in scope of penalties