All posts with the topic: anti-avoidance

Territorial limitations on the scope of UK taxes open up the possibility of tax free property development. At least this is the case for non-UK residents who can arrange matters such that they avoid a permanent establishment in the UK (for example, a site office or show-home) and are resident in a jurisdiction with a … Continue reading Profits from Trading in and Developing UK Land

The Chancellor will deliver his 2016 Budget today.  Press coverage suggests that the public finances allow him limited room to manoeuvre. We anticipate the Budget will include: final rules on the additional 3% stamp duty land tax on the purchase of second homes; a clamp down on the use of personal service companies; an update on the UK’s implementation of … Continue reading Budget 2016

The 2015 Autumn Statement is notable for the lack of significant tax measures. The main tax announcements related to residential property (see our separate blog post). A consultation on the company distribution rules will be published later this year. The government will go ahead with changes to tax as income asset managers’ performance incentives unless … Continue reading Autumn Statement 2015

Some of the measures announced this afternoon in the 2015 Summer Budget are as follows: Corporation tax corporation tax to be reduced to 19% in 2017 and 18% in 2020; corporation tax instalment payment dates brought forward for businesses with profits of £20m; annual investment allowance to settle at a permanent level of  £200,000 from … Continue reading Overview of main measures

The first all-Tory Budget of this most political of Chancellors  will have to balance his stated commitment to cut government spending by £30bn over the next two years with his self-denying ordinance prohibiting increases in NICS, VAT or income tax in this Parliament. He will want to get the economic pain over with as soon … Continue reading July Budget: what we’re expecting

Why the Diverted Profits Tax is both a mistake and ripe for judicial review Last December the Government announced the introduction of a new tax, called the Diverted Profits Tax (“DPT”), “to counter the use of aggressive tax planning techniques used by multinational enterprises to divert profits from the UK.” Rushed through before the election, … Continue reading An Unnecessary Diversion

George Osborne introduced a range of measures yesterday which overall signify bad news for the banks, but facilitate non-bank lending. Some of these were proposals announced in the Autumn Statement but confirmed yesterday. Bank losses: as previously announced, from 1 April 2015 there will be a restriction on the carry forward of losses to 50% … Continue reading More pre-election banker bashing

Today’s budget included the stamping out of various techniques (known as “refreshing” arrangements) that allow companies to use certain types of brought forward losses which might otherwise not be used (sometimes described as being “trapped”). The losses in question are trading losses, non-trading loan relationship deficits (interest expenditure) and management expenses which, in each case, … Continue reading A more straight forward rule would have been refreshing

Tomorrow’s Budget Speech is likely to have a split personality, being the final Budget of the Con/Lib Coalition Government but also an opportunity for this most political of Chancellors to publicise some of the more electorally attractive policies to be included in the forthcoming Conservative manifesto. This blog post concentrates mainly on the former aspect. … Continue reading Budget March 2015: what are we expecting?

A common method of effecting corporate takeovers for many years has been by way of a target company entering into a scheme of arrangement with its shareholders (rather than by way of a standard takeover offer made by the buyer).  This method is used for a number of reasons, including potentially shorter timescales and a … Continue reading Stamping out cancellation schemes