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Budget 2011 implications

Life insurance - Solvency II

The Government has made announcements on the future of life company taxation in the context of the implementation of Solvency II in 2013.

Modernisation of investment trust company rules

The Government has confirmed its decision, initially proposed in a consultation document published on 27 July 2010, to modernise the operation of the tax rules for investment trust companies.

Stamp Duty Reserve tax: Changes to the schedule 19 regime for UK investment funds

Although HMRC will not be abolishing the Schedule 19 regime for SDRT applicable to UK unit trusts and open ended investment companies, Finance Bill 2011 will remove a distortion that discourages UK funds of fund structures investing predominantly in non-UK equity investments via other investment funds.

Undertakings for collective investment in transferable securities

The UCITS IV Directive, which will be transposed into UK legislation on 1 July 2011, presents attractive opportunities for the UK fund management industry.

Introduction of a UK tax-transparent vehicle

The Government will add a new tax-transparent vehicle to its collection of Authorised Investment Funds in 2012 with consultation from June 2011 on the regulatory and tax aspects of the new regime.

Will EIS/VCT upgrades galvanise investment in UK businesses, particularly those in the technology sector?

UK companies looking to raise funds from 6 April 2012 should be galvanised by the prospect of changes to the Enterprise Investment Scheme (EIS) and Venture Capital Trust (VCT) provisions with significant increases in both the tax breaks and investment levels that should qualify.

Solvency II - General Insurance: Claims Equalisation Reserves (CERs)

The government has today signalled a willingness to introduce legislation to continue the tax effectiveness of movements to or from CERs after the introduction of Solvency II. This is both a recognition of the volatile nature of the general insurance business, and an attempt not to diminish the competitiveness of the UK for the insurance industry.

Bank Levy Changes

The Chancellor announced significant changes to Bank Levy today, which brings into question the originally announced intention of the measure.

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