At the end of last year we highlighted important changes to the VAT rules on the cross-border supply of digital services (such as digital downloads, e-books or online gaming) to individual customers, and how, without a financial threshold above which the rules would apply, they would create a costly administrative burden for internet start-ups (our … Continue reading VAT in the Digital Single Market: is help on its way for internet start-ups?
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
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
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
In recent years the Rank Group (“Rank”) has been litigating several VAT claims based on “fiscal neutrality” arguments. There have been many twists and turns in this litigation and the claims have proceeded through the courts in three separate strands. Each of these strands is concerned with a comparison of two types of gambling machine … Continue reading Rank Group: fiscal neutrality case remitted to the First Tier Tribunal
It’s fair to say that the UK tax base has come in for something of a battering recently. Recent media spotlight has focused on the low rates of UK tax paid by multinationals on UK sales and on tax avoidance through offshore structures. The UK has a number of tax regimes which seek to deter … Continue reading Investing abroad – some rare good news
These anti-avoidance provisions seek to prevent individuals avoiding tax by holding assets through non-UK resident structures. The European Commission considers the legislation to be incompatible with EU law and has requested that it be amended, presumably to prevent or restrict its application where the non-UK structures are in EU Member States. There will now be … Continue reading Transfer of Assets Abroad and Section 13 TCGA