Mazars tax news covers everything tax related in the UK from, VAT to the latest HMRC rulings.
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Accelerated payments - Schemes list published
On 15 July, HMRC published a list of tax avoidance schemes whose users may be required to make a substantial upfront payment of tax under the ‘accelerated payments’ regime.
Land & Buildings Transactions Tax sub-sale relief
From 1 April 2015 SDLT will no longer apply to transactions of land situated in Scotland. Instead Land & Buildings Transactions Tax (LBTT) will be charged under the Land & Buildings Transactions Tax (Scotland) Act 2013.
Bupa loss relief scheme succeeds
The Upper Tier Tribunal has accepted that a scheme entered into by Bupa to secure consortium relief losses was successful. Key to establishing the entitlement to consortium relief was establishing that Bupa had beneficial entitlement to distributions from the consortium company. The underlying tax avoidance motive was irrelevant.
Employer deductions: late payment penalty
The cost imposed by HMRC on employers for late payment of amounts deducted under PAYE, NIC, student loan repayments and the employer’s liability to secondary NIC changed from 6 April 2014.
LLP salaried members - 5 July deadline
One area of Finance Bill 2014 to attract the most publicity has been the ‘salaried members’ rules, which may affect members of LLPs and which came into effect on 6 April 2014. It is possible for existing members to avoid these rules by increasing their contributions to the LLP, but this needs to be done by 5 July 2014.
Income tax deduction from interest paid overseas
The First Tier Tribunal (FTT) has ruled again that a UK borrower had to deduct income tax from interest paid to a non-resident lender because thesource of interest was in the UK. The case of Ardmore Construction Ltd addressed the same issue, where interest arises, as the earlier case of Perrin and came to a similar conclusion but by a different route. It is clear from these cases that where a debt is owed by a UK-resident person (company or individual) to a non-resident HMRC will press for income tax to be deducted from the interest.
Icebreaker 2: What Matters is what really happens
The recent Icebreaker 2 decision received considerable press attention. The case concerned claims for loss relief by the members of several LLPs. It highlights that it doesn’t matter what documentation says, if what really happened is different.
Trust simplification sees pilot trusts ejected
The proposals to simplify trust exit and ten-year anniversary charges, due to come into effect on 6 April 2015 have been modified in the consultation document ‘Inheritance tax: A fairer way of calculating trust charges’ issued by HMRC on 6 June 2014.