COVID-19 Developments -
Tax exemptions for coronavirus antigen costs -
Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
1/5/2021
/ Corporate Taxes ,
HM Treasury ,
HMRC ,
Holding Companies ,
Income Taxes ,
International Tax Issues ,
OECD ,
Private Equity ,
Tax Planning ,
Transfer Pricing ,
UK ,
Value-Added Tax (VAT)
On 30 December, the UK government laid regulations that will significantly reduce the type of cross-border arrangement that will need to be reported by UK intermediaries under the so-called DAC 6 rules on 31 January 2021 and...more
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more
UK COVID-19 Developments -
Extension of support for employed and self-employed workers -
On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
12/3/2020
/ Capital Gains Tax ,
Corporate Taxes ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Job Retention Schemes ,
Tax Avoidance ,
Tax Exemptions ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
UK Prime Minister’s statement on COVID-19 -
On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
11/9/2020
/ BEPS ,
Corporate Taxes ,
European Commission ,
Fund Managers ,
HMRC ,
Income Taxes ,
Insurance Industry ,
International Tax Issues ,
OECD ,
OTS ,
Pension Schemes ,
Tax Authority ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 Developments -
Budget Cancelled -
The Government announced on 23rd September that the Budget scheduled for November would, as a result of the ongoing Covid-19 pandemic, now not take place....more
9/29/2020
/ Anti-Abuse Rule ,
European Court of Justice (ECJ) ,
GAAR ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Research and Development ,
Tax Relief ,
UK ,
UK Insolvency Act ,
Value-Added Tax (VAT)
HMRC has updated its guidance on the Coronavirus Job Retention Scheme (CJRS). The changes include the removal of parts of the guidance that related to the application of the CJRS up to 30 June 2020 and to update employers on...more
UK COVID-19 Developments -
Furlough not detrimental to EMI options held on 19 March 2020 -
On 26 June, the government introduced a new provision into the Finance Bill that provides that the period during which an...more
8/5/2020
/ Capital Gains Tax ,
Coronavirus/COVID-19 ,
Employee Retention ,
Employment Tax ,
Furloughs ,
Future Fund ,
HMRC ,
International Tax Issues ,
Limited Liability Partnerships ,
Maternity Leave ,
National Insurance Contributions ,
Startups ,
State Aid ,
Tax Avoidance ,
UK ,
Value-Added Tax (VAT) ,
Working Time Regulations
UK COVID-19 Developments -
HMRC updates its trading activities guidance -
HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
7/1/2020
/ Corporate Taxes ,
Cross-Border Transactions ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Loan Market Association ,
Reporting Requirements ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
UK COVID-19 developments -
Proposed deferral of DAC6 and DAC2 -
The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
6/3/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
EU ,
European Commission ,
HMRC ,
Income Taxes ,
Infectious Diseases ,
International Tax Issues ,
Personal Protective Equipment ,
Tax Deductions ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain...more
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more
In light of COVID-19, and in response to requests from European trade associations, the European Commission has published its proposal to amend Directive 2011/16/EU which deals with various strands of administrative...more
Temporary changes to the statutory residence test for inbound COVID-19 workers -
The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more
5/12/2020
/ Anti-Avoidance ,
Corporate Taxes ,
Digital Services Tax ,
EU ,
European Court of Justice (ECJ) ,
Guidance Update ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Tax Planning ,
UK ,
Value-Added Tax (VAT)
In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that:
Stock transfer forms should not be posted to the Stamp Office. Instead...more
4/9/2020
/ Banks ,
Consumer Financial Contracts ,
Consumer Financial Products ,
E-Signatures ,
Electronically Stored Information ,
Filing Requirements ,
Financial Institutions ,
Financial Markets ,
HMRC ,
Securities ,
Securities and Exchange Commission (SEC) ,
Stamp Duty Land Tax ,
Stocks
Budget Announcements -
The most significant announcements were:
- immediate reduction in the lifetime limit for entrepreneurs' relief from £10 million to £1 million along with some "anti-forestalling" provisions to...more
Earlier this evening (26 March 2020) the UK Chancellor announced the new Self-Employed Income Support Scheme to help the self-employed face the economic hardship wrought by the COVID-19 pandemic. Below are the key...more
As we reported in our Tax Talks blog of 8 January, the Government has carried out a review of the implementation of the changes to the private sector IR35 rules. This review has now completed with the Government confirming on...more
UK General Tax Developments -
HMRC updates to the private sector IR35 rules -
On 7 February 2020, HMRC confirmed that the new private sector IR35 rules will only apply to payments made for services provided on or...more
3/5/2020
/ Collective Investment Schemes ,
Corporate Taxes ,
Employer Liability Issues ,
Foreign Investment ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Private Equity ,
State Aid ,
Tax Planning ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
UK General Tax Developments -
Date set for next UK Budget -
The first Budget of the new Conservative government will be held on Wednesday 11 March. There has been significant speculation that there will be a major...more
1/31/2020
/ Anti-Avoidance ,
Articles of Association ,
Corporate Taxes ,
Draft Guidance ,
Entrepreneurs ,
EU ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Investment Funds ,
Partnerships ,
Private Equity ,
Remuneration ,
Tax Reform ,
UK ,
UK Brexit ,
Value-Added Tax (VAT)
There has been much talk recently about “review and reform” (or abolition) of entrepreneurs’ relief. This seems to have moved a step closer this week with Boris Johnson stating that the Treasury are “fulminating” against it...more
In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment...more
As announced by the Chancellor in the run up to the recent General Election, the Government is launching a review into the implementation of the changes to the IR35 rules for private sector workers scheduled to be introduced...more
UK Case Developments -
IR35 – no mutuality of obligation to create a contract of employment -
RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more
1/6/2020
/ Collective Investment Schemes ,
Corporate Taxes ,
Cryptoassets ,
Employment Contract ,
HMRC ,
Income Taxes ,
International Tax Issues ,
Personal Services ,
Private Equity ,
Remuneration ,
Tax Liability ,
UK ,
Value-Added Tax (VAT)
UK Case Law Developments -
More decisions on IR35 -
This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more
12/2/2019
/ Corporate Taxes ,
Cryptoassets ,
Distribution Rules ,
Employment Tax ,
EU ,
HMRC ,
International Tax Issues ,
Member State ,
OECD ,
Self-Employment Tax ,
UK ,
UK Cryptoassets Taskforce ,
Value-Added Tax (VAT)