Category Archives: Olswang Budget Blog

In today’s Budget, the main news for employee incentives is that the Government has confirmed that it is proposing to continue with the Enterprise Management Incentive (EMI) scheme. EMI share options can be granted by SMEs over up to £250,000 of shares per employee, with exercise gains subject to capital gains tax at 10% under … Continue reading Employee Incentives – Budget developments

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!

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’

The Government has published revised proposals to tax non-UK residents on gains on UK residential property with effect from April 2015.  Non-residents will remain exempt from UK tax on gains on commercial property unless it is used as part of a trade carried on through a UK permanent establishment. The Government has been consulting on the proposals for … Continue reading Non-residents to be taxed on gains on UK residential property

The EU VAT system is set for a significant upheaval come January 2015, potentially causing suppliers of digital products a major headache. The change aligns the rules for both EU and non-EU businesses in relation to the supply of “digital services”, so that VAT is charged on supplies to individual customers in the jurisdiction in … Continue reading Supplies of digital services by EU tech companies

Notwithstanding consultation criticisms it was confirmed today that the Government will press ahead with plans to reduce tax avoidance benefits. It is proposed that Finance Act 2014 will provide HMRC with powers to require a taxpayer to pay tax upfront where: • the taxpayer has entered into arrangements to obtain a tax advantage (whether or … Continue reading More on tax avoidance

Adopted by the ‘Assemblée Nationale’ on 23 October 2012 Article 6 of the draft French Finance Act for 2013, which amends the taxation of capital gains, has been radically changed by the lower court of the French Parliament which voted the draft earlier this week. The new draft proposes (1) to maintain the favourable regime applicable … Continue reading Draft of French Finance Act for 2013 – Focus on capital gains tax treatment

Changes to the scope of Enterprise Management Incentives (“EMI”) options have been announced today which will expand the way in which employees can benefit from EMI options. Entrepreneurs’ relief is currently available to employees and directors who realise “qualifying gains” in respect of shares held in their employing company (or a member of its group). … Continue reading Entrepreneurs’ relief to apply to EMI shares

 The Government has today taken steps to improve and reform the current EMI legislation. The measures are designed to help small and medium enterprises who carry on a qualifying trade recruit and retain high calibre employees. The government has said it will increase the value of tax-advantaged EMI options that can be held by an … Continue reading Enterprise Management Incentives Schemes (“EMIs”)

 As widely predicted, the highest (“additional”) rate of income tax will be reduced from 50% to 45% from 6 April 2013. Given that the introduction of the additional rate has not delivered the additional tax revenues expected, it will be interesting to see if this 5% reduction is sufficient to prevent taxpayers from taking steps … Continue reading Reduction of 50% income tax rate and impact on employee share plans