A few further points.  The 50% levy will not be  deductible for corporation tax purposes. It will be payable on 31 August 2010. Although they are only stated as applying to bonuses awarded or paid before 6 April 2010 one could imagine that date maybe being extended. It is not just banks – UK resident companies … Continue reading Banking bonus – further points

Recent weeks have seen both the French and the Spanish Governments withdraw their sports-related tax breaks. The French have ended their “droit à l’image collectif”, which allowed football clubs to treat up to 30% of a player’s income as a payment for exploitation of their image rights rather than salary, and the Spanish have announced … Continue reading Sports tax

As has already been noted on this site, the condition that companies can claim research & development (R&D) tax relief on qualifying expenditure deriving only from intellectual property that they own has been removed for companies that are small and medium sized enterprises. This change is welcomed but it is disappointing that the Government has not taken the … Continue reading R&D tax relief relaxation

The Chancellor announced a further increase of 0.5% (on top of the 0.5% rise we were already expecting) on employee and employer NICs.  The increase will come into effect on 6 April 2011. This means high earners will have a marginal NICs rate of 2% and companies will have to pay 13.8%. This widens the … Continue reading Surprise NICs increase

Assuming no exemption is available then it seems to work like this: Bank pays £100,000 bonus. Bank is required to pay £37,500 in “supertax” to HMRC (the first £25,000 of the bonus does not attract the supertax). The bonus of £100,000 is then subject to tax and NICs in the usual way. Employer’s NICs of £12,800 (at 12.8%) and income tax … Continue reading Bank Payroll Tax: Example

Finance Bill 2010 will block a potential stamp duty and SDRT avoidance arrangement that arose following the taxpayer’s victory in the HSBC Holdings case in the ECJ (reported here – click here to view) HMRC can no longer apply the 1.5% stamp duty or SDRT charge on new shares first being issued into an EU clearance service … Continue reading Clearance services – stamp duty and SDRT changes

There was little for the film industry to get excited about in today’s Pre-Budget Report.  Thankfully, there is no further specific anti-avoidance legislation.   There was a small tweak to the film tax credit legislation to remove an anomaly which impacted upon the amount of tax credit available where film production spanned more than one accounting period.   I would like to have seen … Continue reading Film

As mentioned already, Alistair Darling announced the 10% rate of corporation tax on income from the exploitation of patents.  What he did not say (but which is in the press releases) is that it is currently proposed that this reduced rate will not apply to income from patents until April 2013.   The Government have said they will … Continue reading More news on the “patent box”

No surprises here ! After weeks of speculation the Government appear to have closed down a loophole which enabled you to circumvent the £2 million limit per EIS/VCT company by amalgamating funds through partnerships.  A new definition of small enterprise is proposed.  It appears that the Government view is that funding large projects with EIS monies intended to promote high risk start up companies is not within the spirit of … Continue reading EIS/VCT restrictions

Analysis from the award-winning CMS Tax Group