The Finance Bill 2018-19 will introduce UK tax currently at 20% on income from intangible property held in low-tax jurisdictions to the extent that the income is referable to UK sales. This measure will come into effect from 6 April 2019. The UK tax will be levied on relevant gross income realised by non-UK resident … Continue reading UK Tax on Offshore Intangibles
HM Treasury has published a position paper in respect of taxing the digital economy (available here) following the Chancellor’s Autumn Budget. The paper proposes that multinational groups’ profits should be taxed where value is generated. For example, a social media business generates value through users worldwide, but is only taxed where it is tax resident … Continue reading Taxing the Digital Economy: first steps by the UK
Following the announcement in the Autumn Statement, the revised draft legislation relating to the new regime on the taxation of termination payments, due to apply from April 2018, was published on 5 December 2016. As presaged by the Chancellor, the legislation has greatly simplified the original proposals, removing the complexity (and the potential unfairness) inherent … Continue reading The new termination payments regime – draft legislation published
Termination payments The Government has announced changes to the way non-contractual termination payments will be taxed from April 2018. The position is complex, but very broadly certain payments which are non-contractual “ex gratia” in nature are tax free up to £30,000 upon termination of employment. The excess is subject to income tax but is not … Continue reading Employment income – selective aspects
When the Finance Bill 2015 receives Royal Assent in the next few weeks it will contain enabling legislation to usher in prescriptive documentation requirements for approximately 1,400 of the largest multi-national enterprises (“MNEs”) with a UK parent. The enabling legislation will give HM Treasury the power to make regulations via statutory instrument to implement the final recommendations for country-by-country … Continue reading Country-by-country, year by year – the compliance burden is increasing!
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
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
Following last week’s blog here, there is good and bad news on the vexed issue of corresponding adjustments for individuals. The bad news is that the harsh new restrictions have been introduced with immediate effect from 25th October. The good news is that the Government has listened to some of the arguments made during the … Continue reading Corresponding adjustments revisited – some Government concessions
In this update, Partner Julien Monsenego and Senior Associate Rui Cabrita of Olswang’s Paris office look at the main tax measures in the French Government’s 2014 budget bill. To view the update, click here.
One of the more ominous announcements in the Budget was the launching of a consultation on tax avoidance through use of LLPs and partnerships. Partnerships and LLPs are well established structures for investment funds and business services, popular due to their flexibility and tax transparency. However, the Government is concerned that this flexibility has … Continue reading Partnerships and LLP anti-avoidance – HMRC’s latest target