Category Archives: Autumn Statement 2014

HMRC representatives have confirmed that the Government intends to press ahead with the introduction of the controversial new Diverted Profits Tax (DPT), referred to in the media as “Google Tax”.  Speaking at an Open Day on 8th January and a conference on 13th January they said the Government intends to include DPT in the pre-election … Continue reading The new UK Diverted Profits Tax

For companies now subject to investigation from an EU State Aid perspective, the potential for repayment obligations are likely to be an unexpected outcome from what many may have regarded as mainstream tax structuring. An outline of the current position is available here.

In his Autumn Statement, the Chancellor announced measures to prevent investment fund managers receiving guaranteed income from investment funds without paying income tax on it as trading or employment income. While this is no doubt targeted at arrangements such as GPLP structures, the draft legislation goes much further and potentially brings carried interest and co-investment … Continue reading Investment Fund Managers: taxation of “disguised fees”

At the start of this Parliament, the Chancellor introduced changes to the non-dom rules and, at the same time, promised no more; thereby assuring us all that there would be some badly needed stability to these rules. Since then we’ve had various changes (not all of which were intended to raise revenues – e.g. business … Continue reading “There will be no more changes to the non-dom rules in this Parliament… Unless we badly need some votes.”

In a highly political Autumn Statement today, George Osborne could not resist another bout of banker bashing. His aim is to ensure that, once banks return to profit after the financial crisis, they pay tax on their profits rather than offsetting the huge losses brought forward from the recession to eliminate profit for what could … Continue reading Bank loss relief restriction – pre-election banker bashing?

Those nostalgic for the glory days of UK children’s TV will be pleased by the extension to creative industry tax credits announced by George Osborne today. Subject to state aid approval, tax relief for the production of children’s TV programmes will be available at a rate of 25% on qualifying core expenditure from April 2015. … Continue reading Tax reliefs to the rescue for children’s TV

A common method of effecting corporate takeovers for many years has been by way of a target company entering into a scheme of arrangement with its shareholders (rather than by way of a standard takeover offer made by the buyer).  This method is used for a number of reasons, including potentially shorter timescales and a … Continue reading Stamping out cancellation schemes

The Government confirmed today that the so-called “late interest” rules are to be abolished in respect of loans made and deeply discounted securities issued between connected companies.  This will affect companies subject to UK corporation tax which have borrowed on deferred interest payment terms from connected company creditors in certain, mainly low tax, overseas territories … Continue reading Abolition of late interest rules for connected companies

The UK Government is keen to be seen as taking the lead in implementing the OECD’s recent recommendations to counteract perceived international tax avoidance. No surprise there given next year’s general election, and it is hybrid structures that are first in the firing line. In brief, hybrid structures seek to take advantages of mismatches between the … Continue reading A wrecking ball for tower structures: major reform of hybrid rules announced

The Chancellor today announced three key measures to help the UK tackle Base Erosion and Profit Shifting (“BEPS”).  The measures signal the first concrete BEPS related measures intended to be adopted into domestic legislation.  The measures are part of the UK Government’s efforts to strengthen anti-avoidance measures and in the process promote fairness in tax … Continue reading BEPS takes centre stage as Chancellor ushers in special ‘Tech Tax’