paulbramall, Author at Gabelle Tax Consultants

Autumn Budget 2018 – Taxation of property gains of non-UK residents

29 Oct 2018

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

22 Nov 2017

Post by paulbramall

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

22 Nov 2017

Post by paulbramall

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

8 Mar 2017

Post by paulbramall

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...