UK amends hybrid capital instruments rules
The ‘hybrid capital instruments’ rules are relied upon since 1 January 2019 by many banks and insurers to give corporation tax relief for the coupon payments on regulatory capital securities. These rules have recently been amended by the
See MoreUK: Updated statistics on creative industries tax relief
On 7 August 2019 HMRC published updated statistics on creative industries tax relief. Film tax relief Film tax relief is given at 25% of qualifying production expenditure and is available in the case of British qualifying films that have
See MoreUK: Summary of responses to consultation on the restriction on offset of capital losses
On 11 July 2019 the UK government published a summary of responses to the consultation on the restriction of carried forward capital losses, which was held between 29 October 2018 and 25 January 2019. Interested parties submitting responses
See MoreUK: Summary of responses to consultation on digital services tax
On 11 July 2019 the UK government published a document summarising the responses to the consultation on the design of the digital services tax (DST). The DST is to be implemented from April 2020. Certain digital business models derive value
See MoreUK: Consultation on tax dispute resolution
On 2 July 2019 the UK government published for consultation draft Regulations to implement EU Council Directive 2017/1852 on tax dispute resolution mechanisms. Under the draft Regulations a stronger system of dispute resolution would be introduced
See MoreUK: Spring Statement 2019
The Chancellor delivered the Spring Statement on 13 March 2019. There were no major tax announcements owing to the uncertainty currently surrounding the UK’s withdrawal from the European Union. UK economic growth is to fall to 1.2% for 2019,
See MoreUK: Consultation on Plastic Packaging Tax
On 17 February 2019 the UK government issued a consultation document on the introduction of a plastic packaging tax, inviting comments from interested parties by 12 May 2019. This consultation follows a call for evidence in March 2018 which
See MoreUK: Support for Tax Capacity Building
On 19 February 2019 the UK’s Department for International Development (DFID) announced new assistance to give support to developing countries in generating greater tax revenue, tackling tax avoidance and creating a level playing field for
See MoreUK: Finance Act 2019 receives Royal Assent
The UK Finance Act 2019 received the Royal Assent on 12 February 2019. The Act includes some of the measures announced by the Chancellor in the Autumn Budget in October 2018. Annual Investment Allowance The Annual Investment Allowance (AIA) is being
See MoreUK: Consultation on stamp duty land tax surcharge for nonresidents
The UK government issued a consultation document on 11 February 2019 in relation to a Stamp Duty Land Tax (SDLT) surcharge on non-UK residents who purchase residential properties in England and Northern Ireland. This surcharge would apply where
See MoreUK: Date of Spring Statement Announced
The Spring Statement is to be announced on 13 March 2019. The Spring Statement is a response by the UK government to the economic forecast by the Office for Budget Responsibility and gives the government a chance to comment on the direction of the
See MoreUK: Use of new technology in tax administration
On 17 January 2019 the Office of Tax Simplification (OTS) issued a paper entitled “Technology Review: A vision for tax simplicity”. This looks at the role of new technology in improving taxpayer experience and taxpayer interaction with the tax
See MoreEuropean Commission to launch proceedings against UK over VAT treatment of commodity traders
It is reported that the European Commission is planning to take a case to the European Court of Justice (ECJ) in relation to the value added tax (VAT) treatment of commodity traders in the UK. The European Commission argues that although the UK may
See MoreUK: New protocol to double tax agreement with Israel
On 11 January 2019 the UK and Israel signed a protocol to update the double tax agreement between the two countries, incorporating tax treaty related recommendations of the OECD project on base erosion and profit shifting (BEPS). The protocol will
See MoreUK: Double Tax Agreement with Guernsey in force
The comprehensive Double Taxation Agreement and Protocol between the UK and Guernsey was signed on 2 July 2018 entered into force on 7 January 2019. When the agreement is in effect in relation the 1955 Arrangement between Guernsey and the UK for the
See MoreUK revises draft corporate tax loss relief guidance
HMRC have updated their draft guidance on administrative requirements for the deductions allowance in relation to restricted corporation tax loss relief. This draft guidance explains the additional administrative requirements included in Corporation
See MoreUK: HMRC launches Profit Diversion Compliance Facility
On 10 January 2019 HMRC launched the Profit Diversion Compliance Facility targeting multinational companies using arrangements that may result in a liability to the diverted profits tax (DPT). These arrangements generally involve the reduction of
See MoreUK: Double tax treaty with Isle of Man enters into force
The double tax treaty between the UK and the Isle of Man entered into force on 19 December 2018. The treaty replaces the 1955 Arrangement between the UK and the Isle of Man for the avoidance of double taxation which ceases to have effect from the
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