Today’s announced increases in SIP and SAYE limits
As part of today's Autumn Statment, it has been announced that there will be increases in the limits applying to HMRC-approved Share Incentive Plans ("SIPs") and Savings-related Share Option Schemes...
View ArticleCapital gains – reduction of exemption period
The Autumn Statement simply states in the context of private residence relief that the final period for exemption will be reduced from 36 months to 18 months from April 2014. To recap - full exemption...
View ArticleNon UK residents investing in UK residential property
It is proposed that non-UK residents should be brought within the charge to tax on capital gains in relation to UK situate residential property. This is proposed to be implemented from April 2015 in...
View ArticleMixed member partnerships – targeting profit and loss allocation abuse
As widely expected, today’s Autumn Statement confirmed that anti-avoidance measures are to be introduced to counteract the use of corporate partners to reduce the income tax liabilities of individuals...
View ArticleFurther boost for the UK creative industries
Building on last year’s announcement to introduce an animation and high end television tax credit in the UK, the Chancellor today confirmed the Government’s commitment to the creative industries by...
View ArticleWorldwide debt cap and CFC changes – anti-avoidance
Among the anti-avoidance measures announced today were two announcements affecting multinational groups. Worldwide debt cap There will be a widening of the definition of group for the purpose of the...
View ArticleChanges to double taxation relief rules to counter avoidance
Among the draft Finance Bill clauses recently published were amendments to the UK double tax relief rules (“DTR Rules”) which are likely to be of interest to many UK based corporates with overseas...
View ArticleOTS Review of partnerships: Some thoughts about entrepreneurs’ relief
One of the areas of difficulty identified by the Office of Tax Simplification in its interim report is how to apply the entrepreneurs’ relief (“ER”) rules to partnerships. Unfortunately, the...
View Article“Salaried Members” of LLPs: re-categorisation of junior partners
After one of the more heated consultations in recent years, HM Revenue & Customs has now published revised guidance on the intended operation of the new “salaried members” rules, which counteract...
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