Technical Updates

Within the original draft Finance Bill 2017 were provisions related to the ‘Requirement to correct certain offshore non-tax compliance’.  Subsequently, these provisions were deleted from that draft Bill due to the snap General Election on 8th June 2017, but they have been reinstated as Schedule 18 in the draft Finance Bill 2017-19, currently at Committee stage in Parliament. WHO…

Many rural landowners looking to diversify their business interests have considered converting property for use as furnished holiday lets. In addition to potentially increasing the property’s yield, particularly if located in a tourist hotspot, there can be valuable tax advantages if the business is sufficiently engaged with the customer experience and goes significantly above that…

This update concerns the significant changes to the timing of Making Tax Digital (‘MTD’) announced in July 2017. For more detailed background information, please see our MTD March 2017 update which is available on our website. 

On 13 July 2017, an updated version of the Charity Governance Code was published by the Charity Governance Code Steering Group. This replaces the Charity Commission’s previous publication, “The Hallmarks of an Effective Charity”, published in 2008.  The Charity Governance Code can be found at the following address: …

Subscription charges are usually standard rated (i.e. subject to VAT at 20%). However, if little or nothing is received in return for the subscription fee, it may be treated as a donation and would be outside the scope of VAT.   Membership subscriptions to charities often include a principal benefit to which all other benefits are supplementary. In such cases the package of…

Offshore life insurance bonds are a popular investment wrapper, usually involving the payment of a single premium which is used to fund an investment portfolio. They are particularly popular among French expats (they are known as “assurance vie”) as they offer tax advantages and more flexible inheritance rules in France.

Note: The government finalised the reform of the non-dom regime, and this was part of the second Finance Act of 2017 which gained Royal Assent on 16 November 2017 - please see our technical update “Reform of the non-dom regime – Summary”.

BLUE CHIP HOTELS LIMITED [2017] BVC 516 Supply of land with no additional services is exempt from VAT provided there is no option to tax to override the position.  Blue Chip Hotels Ltd (BCH) sought to argue that supply of a room in which a wedding ceremony was held fell within the exemption. In reaching its decision the Upper Tribunal considered whether: the customer had the right…

High value UK residential properties occupied by non-domiciliaries have been acquired within a company structure for a variety of different reasons, often for reasons such as privacy or to manage exposure to UK inheritance tax.  The Government introduced new rules with effect from 1 April 2013 to counter perceived (Stamp Duty Land Tax) avoidance resulting from corporate…

On 15 September 2016, new rules came into force in relation to ‘serial tax avoiders’. These rules mean that it may be in the best interests of taxpayers who have used (or are using) tax avoidance schemes to declare to HMRC the use of and leave those schemes as quickly as possible. Tax avoidance schemes that count towards serial tax avoidance status are: Schemes entered into on…

Small entities fell within the scope of FRS102 for accounting periods commencing on or after 1 January 2016. Under FRS102, a notional interest charge, based on a market rate, had to be calculated and recognised in the profit and loss account where the terms of non-fixed term loan were not at an arm’s length price. The terms of loans from directors are commonly at a non-arms’s length…

UK investment management firms currently have to comply with a piece of legislation known as The Markets in Financial Instruments Directive (MiFID). Introduced in November 2007, it sought to improve the competitiveness of financial markets within the European Union by creating a single market for investment services and activities, and to ensure a high degree of protection for…