Non-resident corporate landlords of UK property need to consider their UK corporation tax obligations

For non-resident corporate landlords gains on all UK property (whether residential or not) will be subject to corporation tax on chargeable gains from 6 April 2019.  From 6 April 2020 non-UK corporate landlords of UK property will be within the charge … Continue reading

When is capital expenditure classified as plant or machinery or an excluded structure or building for tax?

The Upper Tribunal (UT) decision in SSE generation is a helpful decision in clarifying the capital allowance distinction between ‘plant & machinery’ and ‘buildings and structures’. HMRC’s appeal against the previous First Tier Tribunal (FTT) decision (see here) was rejected, so that … Continue reading

Customs freight simplified procedure (CFSP) guarantees for import deferred to 30 April 2020

HMRC has issued a note on using simplified declarations for imports. Under the simplified procedure, the first part of the import declaration does not need as much information as a full declaration. When the first part has been approved, the … Continue reading

OECD consults on digital services tax aimed at changing international tax rules

Following a webcast update on 9 October, the OECD has released a consultation on Pillar One (the allocation of taxing rights and review of profit allocation and nexus rules, in particular looking at “user participation”, “marketing intangibles”, and “significant economic … Continue reading

New Business Risk Review (BRR) process in place from 1 October 2019

HMRC has updated its business risk review guidance to deal with the new expanded category assessment that applies from 1 October 2019. The BRR is the process by which HMRC evaluates and discusses with a large business where it thinks … Continue reading

Country by Country reporting (CBCR) extension to the location of taxes paid agreed by EU Parliament

The European Parliament agreed on 24 October that its member states should require multinationals to publicly report those countries in which their tax is paid (rather than just the aggregate tax paid). The EU press release indicates this will allow … Continue reading

Corporation tax deductions on employee share option exercises – consider the method of settlement

HMRC’s employment related securities bulletin for October 2019 has a section on annual reporting of net settled share awards. The deadline employers’ annual reporting concerning employment related securities is 6 July following the end of the income tax year. Whether … Continue reading

Thinking of engaging a contractor or consultant beyond April 2020 – here’s what you need to know…

We are now less than six months away from the introduction of the new off payroll “IR35” legislation, and even with the postponement of the 6 November budget, there is no sign of any delay. Therefore, it is imperative that … Continue reading