All posts with the topic: Capital Gains

The Chancellor has confirmed that certain previously announced corporation tax measures will be going ahead.  Additionally, he also announced a consultation on bringing non-UK resident companies with UK income (e.g. offshore companies carrying on a property business in the UK), which are currently subject to income tax on such income, within the scope of corporation … Continue reading CORPORATION TAX CHANGES – UPDATE

In addition to the changes to the capital gains tax treatment of private equity carried interest announced today, HMRC has published a Consultation Document which appears to be targeted mainly at hedge fund managers. It aims to ensure that individuals who manage funds where the underlying activities are more closely aligned  to trading than investing  pay full … Continue reading Hedge fund managers’ performance incentives: consultation launched

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

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?

Following recent ECJ decisions, the European Commission requested the UK to amend its exit charge for companies moving their tax residence outside the UK. The current provisions deem a migrating company to dispose of, and immediately reacquire, its assets at market value at the time it ceases to be UK resident.  These rules apply to … Continue reading The corporate exit charge

There had been speculation that the introduction of the Annual Residential Property Tax, as well as extension of the capital gains charge, would be deferred. But not a bit of it. The new tax and the extended charge will come into force from 1st and 6th April respectively as originally planned. Whilst confirmed today, details on the precise … Continue reading High-value residential property update

The UK transfer of assets abroad (TOAA) tax regime is designed to prevent individuals using overseas structures to shelter income from UK tax.  An example would be an individual who subscribes for shares in an offshore company, arranges for that company to acquire an income-producing asset and accumulate the income from that asset offshore. The … Continue reading Investing abroad – refinement of new exemptions from UK anti-avoidance

Next week’s Finance Bill will include the new general anti-abuse rule (GAAR) which is expected to come into effect in June or July 2013.  It is perhaps a measure of the changing political climate over the past year that the GAAR, which was initially very controversial in some quarters, is now widely regarded as necessary … Continue reading The GAAR

Under the Government’s proposed initiative to introduce an “employee shareholder” status, employee shareholders will relinquish certain statutory employment rights in return for shares in their employer company on the basis that any future gains on those shares will be exempt from UK capital gains tax. In a previous update we highlighted some key areas of … Continue reading Employee shareholder proposals? Still not convinced

As ever, pages of documents have been published backing up the Chancellor’s Budget speech made earlier today.  We are analysing these and will soon be blogging more in depth analysis but in the meantime here are some headline changes: Corporation tax rate to be 20% from April 2015 – this will match the small profits … Continue reading The headline changes….more to come