Finance Bill 2019-20 measures effective from 11 July or earlier

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Finance Bill 2019-20 measures effective from 11 July or earlier

Finance Bill 2019-20 measures effective from 11 July or earlier

Wed 17 Jul 2019

Below are some notes on Finance Bill 2019/20 measures that took effect from 1 or 24 January 2019 or 11 July 2019.

For a further discussion of the implication of these or any other Finance Bill 2019/20 measures, please get in touch with a member of the Mazars corporate tax or international tax teams.

Corporation tax- treatment of leases under IFRS 16

The FA 2019 Sch 14 changes to the tax treatment of leases will be amended with effect for accounting periods beginning on or after 1 January 2019 to clarify that the schedule applies to all lessees adopting the new accounting standard, whenever they first adopt IFRS 16.

Corporation tax- deferring tax payable re intra-group cross-border asset transfers

Following the First tier Tribunal decision in Gallagher Limited (see TTH 16 April 2019), from 11 July 2019, companies may apply with immediate to effect, to defer payment of up to the amount of Corporation Tax on profits or gains attributable to cross border intragroup asset transfers, for which the due and payable date given by section 59D of the Taxes Management Act 1970 has not yet passed.

Corporation tax and income tax- share loss relief- UK trade requirement repealed

Following a reasoned opinion from the European Commission that UK tax rules were not compliant with EU law principles in some respects, draft legislation has been published amending share loss relief rules for both corporation tax and income tax purposes.  The current provisions requiring the company to have carried on its business wholly or mainly from the UK (ITA 2007 s134(5) and CTA 2010 s78(5)) are repealed with effect for disposals made on or after 24 January 2019.

CGT- relief for losses on loans to traders broadened to include non-UK borrowers

Again following a reasoned opinion from the European Commission, the CGT relief for loans to traders (TCGA 1992 s253) is being widened from being applicable to borrowers resident in the UK, to borrowers resident anywhere in the world with effect for loans made on or after 24 January 2019.

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