Category Archives: Autumn Statement 2013

After one of the more heated consultations in recent years, HM Revenue & Customs has now published revised guidance on the intended operation of the new “salaried members” rules, which counteract what the Government regards as “disguised employment” through the use of LLPs.  The revised guidance addresses some of the concerns raised, highlights HMRC’s highly … Continue reading “Salaried Members” of LLPs: re-categorisation of junior partners

One of the areas of difficulty identified by the Office of Tax Simplification in its interim report is how to apply the entrepreneurs’ relief (“ER”) rules to partnerships.  Unfortunately, the commentary within the interim report itself is not particularly clear as to the precise nature of the problems, so what follows is my list. LLP … Continue reading OTS Review of partnerships: Some thoughts about entrepreneurs’ relief

Among the draft Finance Bill clauses recently published were amendments to the UK double tax relief rules (“DTR Rules”) which are likely to be of interest to many UK based corporates with overseas income streams.   The general aim of the DTR Rules is to allow relief for foreign tax against UK tax on the same … Continue reading Changes to double taxation relief rules to counter avoidance

Among the anti-avoidance measures announced today were two announcements affecting multinational groups. Worldwide debt cap There will be a widening of the definition of group for the purpose of the worldwide debt cap (“WWDC”).  The purpose is to ensure that groups cannot avoid or mitigate the application of the cap by including entities in the … Continue reading Worldwide debt cap and CFC changes – anti-avoidance

Building on last year’s announcement to introduce an animation and high end television tax credit in the UK, the Chancellor today confirmed the Government’s commitment to the creative industries by announcing improvements to the existing UK film tax credit which are also designed to boost the UK visual effects industry.    Subject to state aid approval, … Continue reading Further boost for the UK creative industries

As widely expected, today’s Autumn Statement confirmed that anti-avoidance measures are to be introduced to counteract the use of corporate partners to reduce the income tax liabilities of individuals in partnerships. Very broadly, the Government’s concern is that individual partners have been reducing the amounts on which they are taxed at up to 45% (and … Continue reading Mixed member partnerships – targeting profit and loss allocation abuse

It is proposed that non-UK residents should be brought within the charge to tax on capital gains in relation to UK situate residential property. This is proposed to be implemented from April 2015 in relation to “future gains”. A consultation will be published early in 2014 so at the moment we have few details. It is not clear … Continue reading Non UK residents investing in UK residential property

The Autumn Statement simply states in the context of private residence relief that the final period for exemption will be reduced from 36 months to 18 months from April 2014. To recap – full exemption is available if a dwelling house has been an individual’s only or main residence throughout their period of ownership. Partial exemption … Continue reading Capital gains – reduction of exemption period

As part of today’s Autumn Statment, it has been announced that there will be increases in the limits applying to HMRC-approved Share Incentive Plans (“SIPs”) and Savings-related Share Option Schemes (“SAYE”). Under a SIP, and from April 2014, employees will be able to invest up to £1,800 per year (currently £1,500) from pre-tax salary in … Continue reading Today’s announced increases in SIP and SAYE limits