Technical Updates

Technical updates

understanding your world

technical updates

In-depth analysis of the issues facing our private clients, entrepreneurs and their businesses.

Filter Technical updates

13 September 2019

Demergers - Capital Reduction Demerger

Companies are increasingly turning to demergers as a method of separating out various parts of a business. The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, ring-fencing liabilities, succession planning or shareholder disputes. There are three broad routes to carrying…
Business taxes Technical updates
31 July 2019

Construction Services Domestic Reverse Charge for VAT

HMRC have delayed the introduction of the domestic reverse charge for construction services, with the new expected start date being 1 October 2020.
Business taxes Property VAT Technical updates
31 July 2019

The 5th Money Laundering Directive as it Relates to Trusts

The Government recently published a consultation, ‘Transposition of the Fifth Money Laundering Directive’, which considers the proposals to transpose the EU’s 5th Money Laundering Directive (“5MLD”) into UK law. The Directive affects all UK express trusts and many non-UK express trusts, and extends the reach of the 4th Money Laundering Directive (“4MLD”), which itself…
Compliance Trusts & Estates Technical updates
26 July 2019

Economic substance requirements for companies in Crown Dependencies and other jurisdictions

New legislation has been introduced in the Crown Dependencies of Guernsey, Jersey and Isle of Man, as well as in Bahamas, Bermuda, BVI and Cayman Islands, which now ensures that certain entities based in those territories can demonstrate sufficient local economic substance. The start date varies slightly among jurisdictions, but for the Crown Dependencies the legislation…
Business taxes Compliance Technical updates
23 July 2019

Corporation Tax Treatment of Goodwill and Related Assets

There are special rules governing the treatment of goodwill and other intangible assets for corporation tax purposes. When the rules were first introduced with effect from 1 April 2002 the tax treatment was intended to broadly follow the accounting treatment. This meant that where a company acquired an intangible asset, it would be able to claim a corporation tax…
Business taxes Technical updates
09 July 2019

IHT - OTS second report

The Office of Tax Simplification (OTS) recently published its second report on inheritance tax. The first review was published in autumn 2018 and focussed on administration of the tax. The second review concentrates on the application of inheritance tax reliefs and other technical aspects. The government has not yet responded to the report so it is unclear if any of…
Business taxes Inheritance tax Property Trusts & Estates Technical updates
04 July 2019

Reforms to Off-Payroll Working – Extension to the Private Sector

Update July 2019: In the October 2018 budget it was announced that the off-payroll working rules in the public sector will be extended to the private sector from April 2020. After initial consultation, the government has listened to concerns that these changes may be onerous to implement for the smallest organisations and has decided that they will not apply to small…
Business taxes Compliance Personal taxes Technical updates
21 March 2019

Capital Gains Tax Changes

HMRC have recently introduced several revisions to the capital gains tax (CGT) rules. An outline of the main changes is below.
Personal taxes Property Technical updates
21 March 2019

Structures and Buildings Allowances - Publication of Draft Legislation

A new Structures and Buildings Allowance (SBA) was announced in the Autumn Budget 2018, at which time a Technical Note was published setting out in some detail what was proposed. Since then, HMRC have been in discussions with various interested parties, and as a result there have been some small changes to the proposed relief. HMRC have now published draft legislation…
Business taxes Property Technical updates
21 March 2019

Demergers - Liquidation Reconstruction under s 110 Insolvency Act 1986

Companies are increasingly turning to demergers as a method of separating out various parts of a business. The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, ring-fence liabilities, succession planning or shareholder disputes. There are three broad routes to carrying…
Business taxes Technical updates
19 March 2019

Demergers - The Statutory Route

Businesses use demergers as a method of separating out various parts of a business. The decision to split off a trade or subsidiary from a company or group may be undertaken for a multitude of reasons including streamlining operations, asset protection, succession planning or shareholder disputes. There are three broad routes to carrying out a demerger: The statutory…
Business taxes Technical updates
06 March 2019

The UK Hybrid Mismatch Rules

The hybrid mismatch rules are aimed at counteracting tax mismatches where the same item of expenditure is deductible in more than one jurisdiction or where expenditure is deductible but the corresponding income is not fully taxable (or the income is taxed at a beneficial rate or is deferred to a future period). The rules were introduced in response to the OECD’s base…
Business taxes Technical updates