ECJ: Decision in the Ocean Finance case
The case of Paul Newey (trading as Ocean Finance) concerned a UK loan broker arranging loans between lenders and borrowers within the UK. Mr. Newey set up a Jersey company called Alabaster (CI) Ltd and gave this company the right to use the trading
See MoreUK: Review of bank levy
When the introduction of the UK bank levy was announced in the 2010 budget it was also announced that there would be a review in 2013 to ensure that the levy was operating efficiently. On 4 July 2013 the UK published a consultation document on the
See MoreUK: VAT deductible in respect of certain payments relating to loyalty cards
The UK Supreme Court reached a decision on 20 June 2013 in respect of CRC (Appellant) v Aimia Coalition Loyalty UK Ltd, formerly known as Loyalty Management UK Ltd (hereafter “Loyalty Management”). The company operated the Nectar loyalty card
See MoreUK: Consultation on community amateur sports clubs
The UK government has published a consultation document in respect of tax relief given to community amateur sports clubs. The current relief gives some tax relief that is similar to the relief given to charities, but policy is being reconsidered in
See MoreECJ rules on relevance of contractual terms in VAT supply
The European Court of Justice (ECJ) has reached a decision in the case of HMRC v Paul Newey t/a Ocean Finance (C-653/11). This case concerned the relevance of contractual terms to the identification of the supplier and recipient of services for the
See MoreUK: consultation on allowing the transfer of savings in child trust funds to junior ISAs
The UK government has published a consultation document in respect of allowing the transfer of savings from a Child Trust Fund to a junior Individual Savings Account (Junior ISA). Child trust funds were originally introduced in 2004 with the
See MoreUK: Double tax agreement with the Netherlands on bank taxes
The UK and the Netherlands signed a double tax convention on 12 June 2013 in respect of bank taxes. The taxes covered by the Convention are the UK bank levy under Schedule 19 FA 2011 and the tax charged under the Netherlands law on bank tax. The
See MoreUK: Amendments to the tax treaty passport scheme
The tax treaty passport scheme was introduced from September 2010 to allow a simplified clearance scheme for taxpayers applying for reduced rates of withholding tax on interest under a double tax treaty. An overseas corporate lender in a country
See MoreUK: offshore employment intermediaries
A consultation document has been issued by the UK government proposing measures to deal with issues arising from the use of offshore employers of workers based in the UK to avoid tax and national insurance contributions on wages. The consultation
See MoreUK: Consultation on loan relationships and derivative instruments
The original loan relationships rules issued by the UK government in the 1990s modernized the treatment of debt instruments by aligning the tax treatment more closely with the accounting treatment. However in the meantime the financial world has
See MoreUK: Terms of Reference issued for GAAR advisory panel
The legislation in respect of the General Anti Abuse Rule (GAAR) in the Finance Bill 2013 provides for the appointment of a GAAR advisory panel. The panel is to consider and approve HMRC’s guidance on the GAAR. It is also required to consider
See MoreUK: Strengthening the code of practice on taxation for banks
The HMRC released a consultation document on 31 May 2013 in respect of amendments to the code of practice on taxation for banks. Comments on the proposed changes are invited by 16 August 2013. The provisions of the code cover the required practices
See MoreUK: HMRC guidance the Seed Enterprise Investment Scheme
The HMRC published a series of answers on 28 May 2013 to frequently asked questions about the Seed Enterprise Investment Scheme (Seed EIS). The scheme has been applicable in respect of shares issued after 6 April 2012. The Seed EIS was set up to
See MoreUK: Consultation on the VAT treatment of refunds by manufacturers
The UK issued a consultation paper on 31 May 2013 in respect of the value added tax (VAT) treatment of refunds paid directly by manufacturers to consumers. The current UK VAT law permits a business that is in a direct relationship with a customer to
See MoreUK: HMRC analyses data on tax schemes
The UK tax authority HMRC has received information indicating the extensive use of tax schemes to hide assets in overseas locations and it is working with the governments of Australia and the US to analyze a large amount of data. The data indicates
See MoreUK overseas territories agree to exchange tax information
A number of UK overseas territories and crown dependencies have agreed to exchange information on tax matters with the UK and other major European countries. Anguilla, Bermuda, the British Virgin Islands (BVI), Montserrat and the Turks and Caicos
See MoreECJ: Decision on the inclusion of non-taxable persons in UK VAT groups
The European Court of Justice (ECJ) has issued a decision in respect of a case brought by the European Commission concerning the provision for VAT groups in the UK. The UK argued in support of its position that non-taxable persons could be included
See MoreUK: HMRC announces widespread compliance with real time information
Most UK employers are now required to report their information on wages and deductions under the Pay as you Earn (PAYE) scheme in real time. The UK tax authority HMRC announced last week that more than 680,000 employers have begun reporting PAYE in
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