Category Archives: Budget – March 2014

With all of the focus on next month’s devolution vote in Scotland, it is easy to overlook reports this week suggesting that Northern Ireland’s parliament is likely to be given corporation tax rate setting powers. The debate on whether such a move is desirable and/or compliant with EU law has been rumbling for years. It … Continue reading Northern Ireland: possible corporation tax reduction?

HMRC have now provided further guidance on when the grant of a lease can be a transfer of a business as a going concern (“TOGC”), which is not a supply for VAT purposes.  HMRC’s previous guidance explained that the grant of a lease could be a TOGC provided that the lessor’s retained interest had a … Continue reading New HMRC TOGC guidance

All of the changes to employee share incentive arrangements that were proposed back on 27 March (when the Finance Bill was published) have now formally made it onto the statute books: Royal Assent has been received and we now have the Finance Act 2014.  Just as well really, given that the vast majority of the changes have … Continue reading Employee Share Incentives update: Royal Assent to the Finance Bill

As with London buses, we wait ages for cases on the meaning of UK source and then two come along at the same time! While these two recent First Tier Tribunal decisions, Perrin v HMRC and Ardmore Construction Ltd v HMRC, are broadly consistent with HMRC’s published guidance on when interest is regarded as arising … Continue reading UK source interest and withholding tax: recent decisions

The European Council’s Expert Group on the Taxation of the Digital Economy, which was set up with the task of examining key tax issues relevant to the digital economy (“DE”), issued its final report to the EC on 28 May 2014. The main conclusions are as follows: A separate tax regime for the DE is … Continue reading Tech Sector Update: European Council issues report on the Taxation of the Digital Economy

The Chancellor today published a paper setting out the UK’s priorities for the G20-OECD project on Base Erosion and Profit Shifting (“BEPS”). The paper, titled “Tackling aggressive tax planning in the global economy: UK priorities for the G20-OECD project for countering Base Erosion and Profit Shifting” re-affirms the UK Government’s commitment to adopt any BEPS compliance measures … Continue reading Chancellor sets out the UK’s priorities for the G20-OECD BEPS project

The announcements today by the Chancellor included surprises, confirmed many predictions but some topics were notably absent. Income tax rates – no major review Recent debates on income tax rates have been highly political and will continue to be so as we approach the election. The Chancellor has increased the personal allowance by £500 for … Continue reading Wish you were here: what was missing from Budget 2014?

It might be helpful if I added some context to my avoidance and advance payments outline. According to the impact summary HMRC expect to issue payment notices to around 43,000 taxpayers. Over £5 billion of tax is anticipated to be paid. It is then expected that a range of different legal challenges will arise, including … Continue reading Tax avoidance and accelerated payments – some context

Among the detailed tax announcements today was a measure blocking, with immediate effect, arrangements where profits are transferred between companies in the same group for tax avoidance purposes. Where it applies, the transferor company will be taxed as if the transfer had not taken place and will not be entitled to any tax deduction for the payment.  However … Continue reading Anti-avoidance: Transfer of corporate profits

Today saw the first budget for some years which did not feature a new cut in the corporation tax rate.  Instead, the previous cuts (to 21% for the year beginning 1 April 2014 and to 20% for the year beginning 1 April 2015) were reaffirmed and so it seems clear that the government intends to … Continue reading Corporation tax rates and capital allowances