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: Mark Joscelyne, Tax Partner, Olswang
Transfer of Assets Abroad and Section 13 TCGA
These anti-avoidance provisions seek to prevent individuals avoiding tax by holding assets through non-UK resident structures. The European Commission considers the legislation to be incompatible with EU law and has requested that it be amended, presumably to prevent or restrict its application where the non-UK structures are in EU Member States. There will now be [...]
Controlled foreign companies
As expected, the government has announced that a full reform of the controlled foreign companies (“CFC”) regime will be legislated for in Finance Bill 2012, with the new rules to take effect for accounting periods beginning on or after 1 January 2013. The current CFC regime has been heavily criticised by business in recent years [...]
Posted in Budget - March 2012, CFCs Leave a comment
Corporation tax reform
Whilst it will be the unexpected 2% cut in the main rate of corporation tax which will no doubt feature in the headlines, the radical reform of the tax treatment of foreign profits is perhaps more significant to the international tax competiveness of the UK. The Chancellor was reportedly hoping to announce that at least [...]
Banking bonus – further points
A few further points. The 50% levy will not be deductible for corporation tax purposes. It will be payable on 31 August 2010. Although they are only stated as applying to bonuses awarded or paid before 6 April 2010 one could imagine that date maybe being extended. It is not just banks – UK resident companies [...]
Posted in Olswang Budget Blog, Pre-Budget Report 2009 3 Comments
Worldwide debt cap
The worldwide debt cap (by which interest relief for large groups will be restricted) is to be amended slightly in the Finance Bill 2010. The changes were first announced by a Ministerial Statement on 9 November 2009. The draft legislation has now been released - we’ll update further.
No change to CGT and VAT rates
Despite rumours and speculation there appears to be no change to the rate of CGT and VAT will revert to 17.5% (not higher) as from 1 January.
Bank Levy