UK: 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
See MoreUK: report on the role of large accountancy firms in tax avoidance
The UK’s Parliamentary Accounts Committee (PAC) has issued a report entitled “Tax avoidance: the role of large accountancy firms” criticizing the close relationship between accountancy firms and the tax authorities. The practice of seconding
See MoreUK: the European Commission opens an investigation into the tax relief for video games
The UK is introducing tax relief for the animation, high end TV and video games industry from 1 April 2013. The relief would amount to a 25% tax reduction based on 80% of the production budget of a qualifying animation or video game relating to
See MoreUK challenges financial transactions tax
The UK has launched a legal challenge in the European Court of Justice to the planned financial transactions tax. This tax is to be introduced by eleven European countries under the EU provisions for enhanced cooperation and is planned to go into
See MoreUK: HMRC issues revised GAAR guidance
HMRC’s latest guidance on the application of the General Anti-Abuse Rule (GAAR) was approved by the GAAR Advisory Panel on 15 April 2013. This guidance summarizes what the GAAR is intended to achieve and how it operates to arrive at this
See MoreTreaty between Albania and United Kingdom signed
On 26 March 2013, Albania and the United Kingdom signed a Double Taxation Agreement. The agreement generally follows the provisions of the OECD Model, with some modifications. The agreement will enter into force when the appropriate ratification
See MoreUK Finance Bill 2013 published
Following the Budget announcements on 20 March, the UK published the Finance Bill 2013 on 28 March 2013. The Bill includes a reduction in the main rate of corporation tax to 21% in 2014 and to 20% in 2015. Explanatory Notes to the Finance Bill have
See MoreUK-Budget announcements for 2013
The Chancellor of the Exchequer presented the 2013 Budget to Parliament on 20 March, 2013. The draft Finance Bill is to be published on 28 March. As previously announced, the main rate of corporation tax will be reduced from 23% in April 2013 to 21%
See MoreUK: new double tax treaty with Norway
On 14 March 2013 the UK signed a new double taxation treaty with Norway. When the treaty enters into force it will replace the current treaty which was signed in 2000. The treaty generally follows the provisions of the OECD Model and incorporates
See MoreUK: New double tax treaty with Spain
On 14 March 2013 the UK and Spain signed a new double taxation treaty. The treaty will come into force when the ratification procedures have been completed. When it comes into effect the new treaty will replace the treaty currently in force which
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