Autumn Budget 2018 – Diverted Profits Tax amendments

The Diverted Profits Tax was introduced in Finance act 2015 and its purpose was to prevent the avoidance of tax by corporates in situations where a UK company uses arrangements lacking economic substance to divert profits to offshore jurisdictions...

Read more

Autumn Budget 2018 – Amendments to the UK corporation tax rules surrounding hybrid instruments and permanent establishments.

Currently there are some financial instruments that, due to the differing tax treatment cross border a tax advantage, may be obtained. To align the current UK rules with the European rules two amendments are required. One of the amendments relates...

Read more

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...

Read more

Autumn Budget 2018 – Entrepreneurs’ relief and incorporation relief

Where an unincorporated business disposes of its assets on incorporation in exchange for shares in the new company claiming hold-over relief under s 162 TCGA 1992, for entrepreneurs’ relief purposes the qualifying period re-starts from the date...

Read more

Autumn Budget 2018 – Tax returns submitted on a voluntary basis

There have been a number of recent legal challenges as to how HMRC deal with tax returns submitted voluntarily where the individual, trust, partnership or company had not previously registered with HMRC and/or had not been asked to submit a tax...

Read more