All posts with the topic: Corporation tax

Today saw the first budget for some years which did not feature a new cut in the corporation tax rate.  Instead, the previous cuts (to 21% for the year beginning 1 April 2014 and to 20% for the year beginning 1 April 2015) were reaffirmed and so it seems clear that the government intends to … Continue reading Corporation tax rates and capital allowances

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

Positive growth forecasts and falling unemployment set a positive tone for this year’s Budget speech, although the Chancellor was frank in his admission that the deficit is still too large. He targeted measures to increase saving, investment, building and exports.  We are reviewing the Budget documents which have now been released and will be blogging … Continue reading Export more. Save more. Invest more. Build more.

Despite the gathering pace of the UK economic recovery, the Chancellor has warned that there is a “long way to go” and that 2014 will be “a year of hard truths”.  With the 2015 general election looming, the Budget is likely to be more political than normal.  The Chancellor has said that he will focus … Continue reading Getting ready for the Budget 2014

HMRC have signalled their intention to introduce in FB13 two new TAARs to counter loss-buying, as well as to tighten up the existing rules on capital allowances-buying and loss relief. These changes are to take effect from today (20 March 2013).  As with all anti-avoidance rules, taxpayers will be concerned to establish whether their legitimate … Continue reading New loss relief rules take effect from today

A few interesting tax changes announced today across the funds spectrum: UK authorised funds The 0.5% stamp duty reserve charge on dealings in units in UK unit trusts and OEICs will be abolished from 1st April 2014,  a very welcome change. The Government will consult on a proposal to remove the requirement to withhold tax … Continue reading Investment funds – changes in the Budget

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

Draft legislation has been published intended to “clarify” that companies can only claim CT relief in respect of shares acquired by employees (eg. through share options) if available under Part 12 CTA 2009; relief cannot also or instead be claimed under general accounting principles which require companies to recognise a fair value accounting expense in respect of … Continue reading Deductions for employee share acquisitions

Given the general thrust against cash being returned or otherwise made available to stakeholders in companies without “proper” tax being paid  (eg. the disguised remuneration legislation) it is perhaps unsurprising that various tax planning opportunities around the loans to participator (“LTP”) rules are being blocked. The LTP rules have been in existence for several decades and exist in order to deter close companies … Continue reading Loans to participators

The use of service partnerships has become increasingly common, particularly where the variable pay component is high. Such arrangements typically give rise to NICs advantages, also they side-step certain difficulties that might otherwise be encountered in the context of income tax as it applies to employees. The press release refers to the “disguising of employment relationships”. Hopefully, this … Continue reading Partnerships and LLPs – further thoughts