In-depth analysis of the issues facing our private clients, entrepreneurs and their businesses.
Technical Updates
Autumn 2017 Budget Update
The Autumn Budget 2017 was the first Autumn Budget in almost 20 years, and was the first in the new annual tax policymaking cycle. The aim of moving the Budget from the spring to the autumn is to provide greater tax certainty by consulting on any proposed changes further in advance and amending tax legislation less frequently. In accordance with these objectives, this Budget did not…
Business Investment Relief
Business Investment Relief (BIR) was introduced in April 2012 to stimulate overseas investment into the UK. To further encourage investment, changes to the relief were introduced on 6 April 2017 relaxing certain provisions.
In effect, BIR allows the individual to make a tax-free remittance of their overseas income and gains to the UK, as long as they use the funds for a…
Partnership Taxation
Various types of partnerships may be formed under English partnership law, including general partnerships, limited liability partnerships (“LLP”) and limited partnerships (“LP”).
The general concept of partnerships is that they are transparent for UK tax purposes. However, the taxation of partnerships has seen a number of changes over the past few years with the introduction of…
Requirement to Correct and the Worldwide Disclosure Facility
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.…
BPR on Furnished Holiday Lets
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…
Making Tax Digital - July 2017 Update
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.
Charity Governance Code
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: …
Charities Update - July 2017
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
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.
Reform of the Non-Dom Regime - July 2017 Update
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”.
VAT Update Issue 2 2017
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…
Annual Tax on Enveloped Dwellings
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…