Olswang Analysis - March 2012
Read the detailed analysis by Olswang lawyers on the implications of the March 2012 Budget by clicking on the links below:
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Blog Articles – Budget 2012
- Olswang Budget Blog 2012 – Detailed Analysis
- IR35 / Personal Service Companies
- Non-domiciled individuals
- Statutory residence test
- Personal tax reliefs restricted
- SEIS – attracting investment in start up companies ?
- Increasing reliance on Transfer Pricing principles?
- Bank Levy
- Transfer of Assets Abroad and Section 13 TCGA
- Controlled foreign companies
- Entrepreneurs’ relief to apply to EMI shares
- More on the sub-sale and other general SDLT anti-avoidance measures
- REITs update
- Towards a General Anti-Abuse Rule
- Consultation on the taxation of interest
- Pensions: “no significant” changes to tax relief
- Come back please, Usain Bolt!
- Further gambling duty update
- Enveloping of High Value Residential Properties – some of the detail
- Enterprise Management Incentives Schemes (“EMIs”)
- Reduction of 50% income tax rate and impact on employee share plans
- Support for innovative industries
- Tax Simplification
- EIS/VCT investment limits curtailed
- Fantastic day for the UK Creative Industries
- Comments on the new SDLT and CGT proposals for companies owning residential real estate
- Changes to gambling duties
- Stamp duty shock announcements and a CGT surprise
- Income tax
- General anti-avoidance rule
- Corporation tax rate cut again – 24% from 1 April 2012
Olswang Tax Team Published Articles
Analysis - Discovery assessments post-Hankinson (Tax Journal 2012)
Analysis - Protecting the buyer against IHT liabilities (Tax Journal 2011)
Reviewing Icebreaker (Tax Journal 2010)
Worldwide Debt Cap (Tax Journal 2009)
Writing Off Employee Loans (Tax Journal 2010)
Betting on Europe - Tax regimes for gambling operators in the EU and beyond (Asian Gaming 2010)
Analysis - Tax on Outsourcing Arrangements (Tax Journal 2010)
FA 2010 Analysis - Sideways loss relief (Tax Journal 2010)
2010 tax avoidance case law review (Tax Advisor)
Case Preview: HMRC v Tower MCashback LLP 1 & Anor (UKSC Blog)
"Analysis – Football clubs", Tax Journal, Issue 1052, 20
Matthew Wentworth-May and Louisa Warburton (8 Nov 2010)"CFC reform - are we there yet?" Financier Worldwide, Oct and Nov 2011
Pat Dugdale and Batanayi Katongera"Expert comment on Grays Timber: Impact on unapproved employee share incentive arrangements", Tax Journal, Issue 1017, 11
Michael Deeks (22 Feb 2010)"Tax efficient ownership of UK intellectual property", International Tax Review, June 2011
Batanayi Katongera and Natasha Kaye (23 June 2011)Too Good to be True? The revised Code of Practice on Taxation for Banks (Tax Journal 2010)
VAT focus – Mobilx Ltd and MTIC fraud (Tax Journal 2010)
Analysis – Tower MCashback: impact on closure notices (Tax Journal 2011)
"Something Nasty in the Greenhouse", Tax Journal, Issue 1006, 11
Hartley Foster (23 Nov 2009)Analysis – Icebreaker and ICTA 1988 s 74 (Tax Journal 2011)
Olswang Budget Analysis Pages
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Olswang Analysis - March 2011
Read the detailed analysis by Olswang lawyers on the implications of the March 2011 Budget by clicking on the links below:
Olswang Analysis - June 2010
Read the analysis by Olswang lawyers on the implications of the June 2010 Budget by clicking on the links below:
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Olswang Analysis - March 2010
Read the analysis by Olswang lawyers on the implications of the March 2010 Budget by clicking on the links below:
Article Categories
- Bank Levy (3)
- Bank Payroll Tax (1)
- Budget – June 2010 (17)
- Budget – March 2010 (16)
- Budget – March 2011 (21)
- Budget – March 2012 (32)
- Budget Update (31)
- Capital Allowances (1)
- Capital Gains Tax (8)
- CFCs (1)
- Corporation Tax (2)
- EIS and VCT Relief (3)
- Employee Incentives (7)
- Film Tax Relief (1)
- Gambling (5)
- Income Tax (5)
- NIC (3)
- Olswang Budget Blog (37)
- Patent Box (3)
- pensions (1)
- Pensions Tax Relief (2)
- Pre-Budget Report 2009 (23)
- R&D Tax Relief (3)
- SDLT (9)
- Tax Avoidance (3)
- VAT (2)
- Video Games Tax Credit (2)
Author Archives: Graham Chase, Tax Partner, Olswang
Towards a General Anti-Abuse Rule
Following recent publicity surrounding a certain UK bank avoiding tax on a purchase of own debt the odds could only have shortened on the introduction of a GAAR. But it might be that the die was cast somewhat earlier when the Court of Appeal found for the taxpayer in the case of Mayes. In the context of a highly engineered [...]
Posted in Budget - March 2012, Tax Avoidance 2 Comments
Income tax
The Chancellor announces that the additional rate of income tax will be reduced from 50% to 45% from 6 April 2013.
Posted in Budget - March 2012, Income Tax Leave a comment
General anti-avoidance rule
The Government is persuaded that a general anti-avoidance rule should be introduced. This is proposed for 2013 following a further period of consultation.
Posted in Budget - March 2012, Tax Avoidance Leave a comment
Enterprise Zones
Up to 21 zones are proposed to be created, but there is no detail regarding the availability of enhanced capital allowances. The Budget report simply states that the Government will work with individual LEPs to consider the scope for introducing enhanced capital allowances to support zones where there is a strong focus on high value manufacturing. Whilst [...]
Income tax rates and high earners
There was no change to income tax rates, which remain at 2010/11 levels. Whilst high earners will be disappointed by retention of the 50% rate, the Chancellor did stress that it was a temporary measure and acknowledged that it could do lasting damage to the British economy. Realistically, it is difficult to see what else the Chancellor could say. The proposed increase [...]
Posted in Budget - March 2011, Income Tax Tagged high earners, income tax, personal allowance Leave a comment
REITs update
An informal consultation is announced with a view to reducing barriers to entry and investment for existing and future REITs. Legislation is proposed to be included by Finance Bill 2012. Few details are provided but overall this looks to be good news for the sector. Of particular interest are: 1. the suggestion that institutional investors might establish REITs; [...]
SDLT anti-avoidance
Notwithstanding the introduction of a general anti-avoidance rule in 2006, opportunities to avoid SDLT continue. To counter this three changes are announced: Sub-sales Where the sub-sale provisions apply there is normally a single charge, payable by the sub-purchaser. However, if the sub-sale rules apply and the sub-purchaser can take advantage of an exemption then no charge [...]
R&D deja vu
Qualifying expenditure on research and development benefits from enhanced tax relief, an additional 75% is available for “SMEs”. For accounting periods ending on or after 9 December 2009 the intellectual property ownership requirement is abolished. All good stuff. Except that this press release is simply a reissue from 9 December. The new note supersedes the [...]
All things green
Apart from the Chancellor’s tie there was little in the Budget that caught the eye. The climate change levy is set for review in Autumn, funding options for the Green Investment Bank are to be considered and there is talk of a new Green Deal for households relating to home efficiency improvements. A consultation on aviation [...]
REITs update