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Financial services tax

Our Financial Services tax team is headed up by Howard Jones, tax partner, specialising in corporation tax for UK and international businesses. Our dedicated teams consist of chartered tax advisers, chartered accountants, solicitors and ex-HMRC officials, which ensures that we can provide truly customised solutions.

Our extensive experience provides us with a broad and deep knowledge of the solutions that have proved successful with our clients plus excellent insights into the policies and procedures adopted by tax authorities. We offer a real value for money service working with your businesses to make sure you stay ahead in this ever-evolving and pressured environment .

Mazars global portfolio includes over 334 listed companies quoted on 16 different stock exchanges. Our focus on quoted companies large private companies and public sector bodies enables us to bring together people from around the world for international assignments.

In particular, at Mazars Financial Services Tax, our advisers can help you with all the tax issues relating to:

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Featured articles

New legislation on UK Protected Cell Companies

By virtue of Regulations which came into force on 21 December 2011, the UK is now able to compete more effectively with other offshore centres like Ireland, Luxembourg, Jersey, Guernsey and Bermuda in terms of being able to offer the security of segregated liability to investors in the sub-funds of an umbrella OEIC.

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.

Collective investment in transferable securities

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

Stamp Duty Reserve tax: Changes to the schedule 19

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.

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.

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.

The FII Group Litigation Order

This article considers what scope is left for institutional portfolio investors such as investment funds and life insurance companies to reclaim UK corporation tax on overseas dividends paid to them before 1 July 2009 following February’s Court of Appeal decision in the case of Test Claimants in the FII Group Litigation v Revenue and Customs Commissioners. The case was brought about by UK parents of international groups, but the various stages of the case also impact on portfolio dividends.

Transfers of business: Amalgamation and Conversion of Mutual Societies

The Regulations announced in the 2009 Pre-Budget report and discussed in our article.

Other articles

Demise of the 1.5% “Entry Charge”?

A decision is expected later this year from the European Court of Justice on the SDRT case of HSBC Holdings plc and Vidacos Nominees Limited v The Commissioners of HM Revenue & Customs, referred by the Special Commissioners.

Worldwide debt cap:Financial Services Exclusion

Multinational groups should now review their business to consider whether they can benefit from the exclusion available to financial services groups or whether they should consider restructuring their business or financing arrangements.

Credit Crisis: stock Lending and repo arrangements

The Finance Act 2009 includes provisions giving relief from stamp duty/SDRT in the case of stock lending or repos arrangements where one of the parties becomes insolvent on or after 1 September 2008.

Related articles

Demise of the 1.5% “Entry Charge”?

A decision is expected later this year from the European Court of Justice on the SDRT case of HSBC Holdings plc and Vidacos Nominees Limited v The Commissioners of HM Revenue & Customs, referred by the Special Commissioners.

Credit Crisis: stock Lending and repo arrangements

The Finance Act 2009 includes provisions giving relief from stamp duty/SDRT in the case of stock lending or repos arrangements where one of the parties becomes insolvent on or after 1 September 2008.

Transfers of business, amalgamation and conversion of mutual societies

The Finance Act 2009 contains new powers to regulate various tax consequences regarding transfers of business from mutual societies (building societies, industrial and provident societies and friendly societies), their amalgamation and their conversion into companies .

The Dixons case

The insurance captive of a UK group selling electrical goods to the retail market backed the latter’s extended warranties on those goods. An unconnected third party entered the contract with the clients and reinsured/insured 95% of its risk with the captive. The third party was introduced to the customer by a member of the UK retail group, to which it paid commission. It was held that under the arm’s length principle, this was not sufficient as the insurance captive should also pay commission to the retail group in return for the exclusive opportunity of obtaining that insurance business. Because of the transfer pricing principles established, the case potentially has implications beyond the limits of its particular facts for financial services groups with interdependent products and services. If once you have read it you wish to discuss how the issues raised by the case could affect the cross-border arrangements of your enterprise, please do not hesitate to call your usual Mazars contact.

Worldwide debt cap:Financial Services Exclusion

Multinational groups should now review their business to consider whether they can benefit from the exclusion available to financial services groups or whether they should consider restructuring their business or financing arrangements.

Related pages

Corporate finance

Wherever you plan to take your business, and whatever your ambition, our Corporate Finance specialists can help you every step of the way.

Financial Services Regulatory

The Mid Market regulatory team links with the outsourced and audit teams to provide the expert assistance you need to meet your obligations in the most efficient manner.

Project Finance and Modelling

Our vision is to establish Mazars as the pre-eminent financial advisory firm in the global infrastructure market. We are one of the few firms who are able to combine market leading expertise with deep knowledge of our chosen sectors - our difference is being able to deliver that capability worldwide as one team

Transaction services

Whether you are looking to grow organically or by acquisition, IPO on a stock exchange, or divest parts of your business, we are able to provide you with a wide range of transaction related services that add real value.

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