Technical Updates

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 the…

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 companies as…

HMRC have recently introduced several revisions to the capital gains tax (CGT) rules. An outline of the main changes is below.

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 which, subject…

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 out a…

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 route (an…

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 erosion and…

The Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS) are designed to help businesses raise finance by offering investors generous tax breaks. These schemes are particularly popular with new companies as they help attract investors. While the tax relief for investors is extremely beneficial, ensuring that all the conditions to qualify for the relief…

Please download the pdf to view the French Tax Data Card 2019.

The Withdrawal Agreement, which was roundly rejected by Parliament on 15 January 2019 following agreement in principle with the European Union on 25 November 2018, provides that VAT and customs processes in relation to trade between the UK and the EU will not immediately change when the United Kingdom leaves the EU at 11pm GMT on 29 March 2019. The Agreement envisages that the…

HMRC recently published a new consultation ‘The Taxation of Trusts: A Review’ considering whether the current system for taxing trusts meets the key principles of transparency, fairness, neutrality and simplicity. The consultation covers the three direct taxes which apply to trusts: income tax, capital gains tax and inheritance tax. The consultation had been trailed in the Spring…

This update concerns the significant changes to the timing and scope of Making Tax Digital (‘MTD’). For more detailed background information, please see our MTD March 2017 and July 2017…