Author Archives: paulbramall
Autumn Budget 2018 – Taxation of property gains of non-UK residents
Where non-residents hold UK property other than UK residential property, then there is no UK capital gains tax on disposal of such property, unlike residential property which has been within the charge since April 2015. Also, the sale of shares in a...
Autumn Budget 2017: Restriction of Double Tax Relief for Permanent Establishment Losses
Companies with overseas Permanent Establishments (PE) can offset losses against their UK profits in the year the losses arise and thus reduce their UK tax liabilities. However, those losses may also be used overseas to frank other foreign profits...
Autumn Budget 2017: Powers to Implement the Multilateral instrument
Currently, the legislation relating to double tax treaties and the reliefs they offer is found in TIOPA 2010 and IHTA 1984. Whilst the relief will broadly remain the same the treaties are going to be revised. Many international companies...
Spring Budget 2017 – International Corporation Tax Changes and an extension to the Double Tax Treaty Passport Scheme
The proposed amendments in the international corporate tax sphere are minor adjustments to existing legislation. The first amendment relates to the Passport Scheme which applies to UK corporate borrowers paying interest to non-UK corporate...
Budget 2017 – How it may affect you
Budget 2017 - How it may affect you. Click on the graphic...
