Possible changes to CGT – Update on the latest OTS review
The Office of Tax Simplification (‘OTS’) has published the first stage of its highly anticipated review of Capital Gains Tax (‘CGT’)...
The Office of Tax Simplification (‘OTS’) has published the first stage of its highly anticipated review of Capital Gains Tax (‘CGT’)...
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...
From 6 April 2020, UK taxpayers who dispose of residential property, will be required to report the disposal and pay the relevant Capital Gains Tax (“CGT”) liability within 30 days from completion. How are residential property disposals reported currently? At...
It seems that HMRC is immune to the very behavioural techniques which it has so enthusiastically adopted (such as the use of “nudge letters”) to influence taxpayers’ behaviour in complying with the UK tax legislation. In our blog on nudge...
HMRC has added guidance to its CIRD manual on the new 6.5% per annum writing down allowance (WDA) in respect of goodwill and related intangibles (referred to collectively as “relevant assets”). To qualify for the relief, relevant assets must either...
The Taxes Acts allow taxpayers to ask for an independent review of an appealable decision by HMRC. The review is carried out by an independent officer within HMRC’s Appeals and Reviews teams. However, recent evidence suggests that many taxpayers remain...
In a backbench revolt on 1 May 2018 the UK Government was forced to back new legislation which will introduce public ownership registers in Britain’s 14 overseas territories. The concept of public ownership registers was originally proposed by David Cameron...
The UK Government has introduced a raft of legislation to address tax evasion and latterly tax avoidance. This has included; The Requirement to Correct legislation which has introduced punitive offshore penalties and extended assessing time limits for Income Tax, Inheritance...
In its pursuit of stamping out tax avoidance HMRC complained to the Advertising Standards Authority (ASA) about misleading tax claims by the promoter, CDP Tax & Wealth Limited, which trades under the name Fiducia Wealth and Tax (FWT). FWT’s website...
It’s often asserted that one of the easier entrepreneurs’ relief (ER) conditions to meet is that the owner of a qualifying shareholding must be an employee of the company throughout the year preceding the disposal of the shares or cessation...
The Government has used the Autumn Budget to again send a clear message of its commitment to tackling tax avoidance and tax evasion especially in relation to offshore structures. The Government will soon be publishing the responses to a consultation document...
The documentation supporting the Chancellor’s 2017 Autumn Budget included confirmation that the draft anti-avoidance legislation published in September will come into effect from 6 April 2018, with only a few very minor updates. The purpose of the legislation is to...
Following the introduction in 2015 of a new capital gains tax regime for non-UK resident individuals who dispose of UK residential property, it is perhaps unsurprising that the Treasury published a consultation document as part of the Autumn Budget proposing...
Rules will be introduced to simplify and to prevent manipulation of pre-existing rules to reduce tax payable on disposal of carried interest. On disposal of carried interest, certain amounts were excluded from capital gains tax where they related to a...
The Treasury have published the results of the Consultation on Financing Growth in Innovative Firms (it was more commonly called the Patient Capital Review). A two page Action Plan has also been published. The ambition of the document was to...
There is more in the Budget about poor productivity in the UK with the OBR revising down productivity growth projections, but seemingly no recognition of the fact that the UK tax framework completely undermines productivity growth in the all-important mid-market...
As most affected people will be aware there is a new relief proposed for anyone who has claimed the remittance basis in the past due to having a non UK domicile of origin and who becomes deemed domiciled in the...
There is an old and bad joke that says that the difference between HMRC and a rabid Pit Bull terrier is that, if you batter a rabid Pit Bull Terrier long enough, it might eventually let go, whereas HMRC… But...
It is said that the real sign that a ship is in trouble is not when the rats jump overboard but when the officers abandon it mid-voyage. If that’s the case, HMRC appears to be sinking because a number of...
HMRC have announced their view that a scheme that its promoters claim converts earnings of the owner/managers of trading companies, in particular personal service companies (PSCs) from income to chargeable gains which attract only the 10% entrepreneurs’ relief rate of...
Whilst taper relief (TR) is long gone its effects still surface occasionally, so it is worth noting the Case of Stolkin v HMRC ([2016] EWCA Civ 447) which concerned the order in which reliefs are applied. Stolkin is only relevant...
Capital Gains Tax (‘CGT’) charged on gains realised on most assets will fall by 8% to 20% (10% for basic tax payers) from 6 April 2016. Long-term investors will be able to claim investors’ relief on gains realised after three...
The changes to the taxation of dividends from 6 April 2016 will see the differential between the rate of income tax on a distribution (up to 38.1%) and that of capital gains tax (as low as 10%, where entrepreneurs’ relief...
The payment window for capital gains tax (CGT) due on the disposal of residential properties will be reduced dramatically from April 2019, but little is known as to how this will work. The Chancellor has announced that from April 2019,...
Will the Autumn Statement change entrepreneurs’ relief? There is widespread speculation about the possibility of the Chancellor making further changes (restrictions) to entrepreneurs’ relief (ER) when he makes his Autumn Statement next Wednesday, 25 November. His previous reforms have not...
In recent years we have witnessed cross-party political support for employee ownership in the UK. The current Conservative and Liberal Democrat coalition have, for example, introduced a number of very welcome changes, notably in Finance Acts 2013 and 2014, which...
The Budget introduces changes to Capital Gains Tax: entrepreneurs’ relief that will affect individuals who wish to benefit from entrepreneurs’ relief (ER) on capital gains tax (CGT) without holding at least a 5% stake directly in a company carrying on...
The Budget introduces changes to Capital Gains Tax entrepreneurs’ relief that will affect individuals and members of partnerships who sell personal assets used in a business but do not, at the same time, dispose of a significant holding of shares...
A tax change that the Chancellor didn’t mention in the House of Commons today will increase tax on shareholders of quoted companies that make a return of capital or pay a special dividend. These groups often give shareholders the choice...
Some have greeted National Audit Office (NAO) report “The effective management of tax reliefs”, issued on 21 November as if it creates a threat to certain tax reliefs, including entrepreneurs’ relief (ER) from capital gains tax (CGT). That is not...
The Upper Tribunal (Lands Chamber) reviewed the basis of apportioning the sale price of land between CGT exempt and taxable parts. They decided HMRC’s approach was fundamentally flawed. Despite the taxpayers neither appearing nor being represented at the UT hearing,...
The First Tier Tribunal (FTT) in Nicholas Trigg v HMRC found in favour of an appellant who held ‘future proofed’ bonds that would convert to euros if the UK adopted the euro. Trigg bought the bonds second-hand at a price...
This was in effect an employment status case but in the context of entrepreneurs’ relief (ER) where the taxpayer needed to establish that he was an employee or office-holder, as opposed to the more usual scenario where the taxpayer claims...
Background In March 2014, HMRC issued a consultation document about implementing a capital gains tax charge on non-residents. Historically, non-residents, whether they be individuals, companies or trusts, have not been liable to CGT on gains on residential properties. However, in...
In the First Tier Tribunal (FTT) case of Rice v HMRC a car trader successfully appealed against HMRC’s refusal of entrepreneurs’ relief (ER) on the sale of his business premises. Mr. Rice had traded for years from a showroom and...
The automatic exemption from capital gains tax for the final period of ownership of former principal private residences (PPRs) will be halved to 18 months from 6 April 2014. This change may affect people who still own a property which...
The recent case of Julian Blackwell v HMRC considered whether the cost of getting out of an agreement could be treated as enhancement expenditure for capital gains purposes. Mr Blackwell’s holding of “A” shares in the eponymous publishing company (“BPH”)...
This website uses cookies.
Some of these cookies are necessary, while others help us analyse our traffic, serve advertising and deliver customised experiences for you.
This website cannot function properly without these cookies.
Analytical cookies help us enhance our website by collecting information on its usage.
We use marketing cookies to increase the relevancy of our advertising campaigns.