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Sweeping CFC Reforms will affect International Groups

UK companies with overseas subsidiaries or associates need to understand how significant changes to the UK’s controlled foreign companies (‘CFC’) rules will affect them so that their tax position is optimised. The changes are expected to come into effect later this year.

19 January 2012

Remuneration Planning Fails at Court of Appeal

A scheme aimed at rewarding employees through special dividends rather than bonuses has failed at the Court of Appeal, with the result that the ‘dividends’ are subject to both PAYE and NIC. The decision could have implications for other employers where dividends have been used as a substitute for remuneration.

22 December 2011

Company Dissolutions and ESC C16

Significant changes affecting company dissolutions are expected to come into effect from 1 March 2012. Many individual shareholders will pay less tax if the company is dissolved under the current concessionary treatment in ESC C16.

22 December 2011

Non-domicile taxation and statutory residence test

Recently the UK Treasury published its core reforms to non-domicile taxation, incorporating the introduction of a higher level of remittance basis charge, a new relief to encourage business investment in the UK and some simplifications to the existing rules. These will be detailed in the Finance Bill 2012 as announced in Budget 2011.

16 December 2011

Monthly Tax Idea – December 2011

Tax exemption for groups selling a property.

14 December 2011

Refurbishing property investment funds

The two special tax regimes to promote commercial and residential property portfolio investment funds in the UK are being further amended to make them more competitive.

09 December 2011

Companies in line for 10% tax on patents profits

...if they can handle the tax complexity. Draft legislation to implement the proposed “patent box” has been published. From April 2013 companies with exclusive rights to patents will pay tax at an effective rate of 10% on some of their profits.

07 December 2011

Taxation of UK based multinationals – Controlled Foreign Companies

The much awaited reforms of the Controlled Foreign Companies rules have been published, aimed at making the UK an attractive place for multinationals to set up parent companies or intermediate holding companies. The key challenge for the Government has been to modernise the CFC rules and target them better: the rules are indeed a complete overhaul.

07 December 2011

Tax changes to encourage business?

The government is looking to businesses to spearhead the recovery from recession. Details are announced in the Finance Bill today of tax changes aimed at businesses of all sizes. Some provide tax incentives to invest in companies, others to attract mobile international businesses to locate in the UK (and indeed for UK multinationals to retain their headquarters here).

06 December 2011

Research & Development Gets a Boost

Both the SME and large company R&D schemes get a boost in the Finance Bill.

06 December 2011

Son of EIS?

SEIS (not Son of EIS but Seed Enterprise Investment Scheme) is one of the new measures trailed in the Chancellor’s Autumn Statement with more detail in today’s draft Finance Bill 2012.

06 December 2011

Land Remediation Relief Survives the Chop

The Office of Tax Simplification had identified LRR as one of a number of tax reliefs to be abolished in the interests of simplicity. Fortunately, this relief has won a reprieve.

06 March 2011

An Inheritance Tax relief for home owners in the South East?

Today's Finance Bill includes details of this new relief announced in the Chancellors Autumn Statement.

06 December 2011

Finance Bill 2012 - Capital Allowances on Fixtures

Earlier this year the Government consulted on changes to the capital allowances which give businesses tax relief on some of their expenditure on buildings. The changes had the objective of clamping down on ‘late claims’ for “fixtures” in buildings and that tax relief should be given on no more than the cost of an asset over its economic life. The draft legislation has moved on somewhat from the previous proposals.

06 December 2011

The new regulated asset pooling vehicle – a UK tax-transparent fund

On the occasion of the March 2011 Budget, HMRC announced that a tax consultation would take place in June this year with a view to introducing a new category of Authorised Investment Fund which would be constituted as a tax-transparent fund (“TTF”) in the UK.

06 December 2011

Autumn Statement: Chancellor offers tax breaks to boost SMEs

Chancellor George Osborne delivered the Autumn Statement on 29 November 2011. Whilst the focus was very much on the state of the UK economy, there were a few references to tax changes.

29 November 2011

Monthly Tax Idea – November 2011

Entrepreneurs’ relief – when £10 million is just not enough.

Company Dissolutions, Bona Vacantia

The Crown’s waiver of property up to £4,000 on a company’s dissolution is being removed from 14 October 2011, and the current concessionary tax treatment has a limited shelf life.

10 October 2011

National contacts

Tim Davies

Tim Davies

Partner
+44 (0)20 7063 4564

Ross Mackenzie

Ross Mackenzie

Partner
+44 (0)141 225 4904

Lindsay Pentelow

Lindsay Pentelow

Partner
+44 (0)1908 257170

MTI

Monthly Tax Idea – December 2011

14 December 2011

Tax exemption for groups selling a property.

Related content

Budget 2011

Mazars issues cautionary welcome to improved tax breaks for companies and entrepreneurs.

Global Transfer Pricing Insights - Autumn 2010 Cover

Global Transfer Pricing Insight - Autumn 2010

Our Autumn/Winter edition of Global Transfer Pricing Insight, now released, contains a number of very topical issues such as joint transfer pricing audits, which pose a significant risk to taxpayers with cross border intra-group transactions.

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