Category Archives: Budget – March 2010

The Government has confirmed that tax relief restrictions on pension contributions for high earners will apply from next year for those with incomes of £150,000 or over. Essentially, tax relief on pension contributions will be restricted for those on “gross incomes” of £150,000 and over, gradually tapering down so that for those on incomes of … Continue reading Pensions after 2011 – some more detail but not the full picture

There was little of excitement in today’s Budget for the UK film industry.  However, HMRC is continuing to target the UK film industry through the number of enquiries and litigation in relation to perceived film tax avoidance structures.  Thus far, HMRC is not having much success.  We were very pleased to see the recent  Court of Appeal decisions in Halcyon and Microfusion, cases which the … Continue reading Film

Some clarity concerning the anti-avoidance measures may be starting to emerge. Existing opportunities arise because transactions involving partnerships are dealt with under schedule 15 FA 2003, which schedule provides a complete code. Mitigation is possible by ensuring that the appropriate degree of connection exists as between the vendor and one or more partners in the purchasing partnership, so that … Continue reading SDLT and partnerships – some further thoughts

It has been confirmed that legislation in Finance Bill 2010 will introduce the bank payroll tax (“BPT”). The Chancellor announced that BPT “has raised £2bn, more than twice as much as was forecast” and, although there was speculation that the tax would be extended, BPT will have effect only from 9 December 2009 until 5 … Continue reading Bank Payroll Tax

In their update on enforcement and compliance, the Government have announced that they will be taking action to prevent attempts to avoid avoid tax and National Insurance contributions through the use of employee benefit trusts and other arrangements to disguise payments of remuneration.  It intends to introduce such anti-avoidance legislation to take effect from 6 April 2011. … Continue reading EBTs and employment-related securities anti-avoidance

Possibly. Under the first quasi-amnesty, the Offshore Disclosure Facility (“ODF”) of 2007, taxpayers who had undeclared offshore income were invited to come forward and self-assess 20 years of undeclared tax liabilities in return for a 10% penalty. This was then followed by the New Disclosure Opportunity (“NDO”), which started in September 2009 and which has … Continue reading Are yet more tax amnesties in the pipeline?

Alistair Darling did not mention gambling taxes at all in his Budget speech, although he did mention the Government’s plan to sell the Tote.   On the Tote, following Gerry Sutcliffe’s recent announcement of the intention to allow the Tote to offer pool betting on sports other than horse racing, the Chancellor has announced that it … Continue reading Gambling

Businesses are already able to claim 100% allowances on most expenditure on plant and machinery up to an annual allowance of £50,000. From 1 April 2010 this limit will be doubled to £100,000. Groups of companies share a single allowance between them and this rule remains, as do restrictions on companies and qualifying activities under common … Continue reading Annual investment allowance

The Government has confirmed its plans, announced in the Pre-Budget Report (PBR) 2009, to introduce a reduced rate of corporation tax of 10% for income from patents from April 2013, in a bid to encourage more products being manufactured in the UK. The PBR 2009 stated that it would apply to patents granted after the Finance Bill … Continue reading Patent box confirmed

The press releases confirm that stamp duty land tax (SDLT) anti-avoidance legislation will be introduced in the Finance Bill 2010 “to target those who exploit the SDLT partnerships rules to reduce artificially the SDLT payable on some land transactions”. From the basic details which have been outlined in the press release, it seems that the existing general anti-avoidance … Continue reading SDLT partnership anti-avoidance