Author Archives: Natasha Kaye, Tax Partner, Olswang

More on the sub-sale and other general SDLT anti-avoidance measures

A stamp duty land tax (SDLT) anti-avoidance scheme that has been widely used by residential purchasers has been stopped by measures announced in the Budget. The scheme broadly involved the purchaser granting an option simultaneously with completion of the acquisition of the property to an unconnected third party, exercisable many years in the future.   The [...]
Posted in Budget - March 2012, SDLT, Tax Avoidance | Leave a comment

Consultation on the taxation of interest

The Government has announced plans to consult on possible changes to the way interest (and interest like returns) are taxed.   The consultation will extend to the circumstances in which tax needs to be withheld from interest payments.  Any changes to this regime will likely have a significant impact on the way many businesses are [...]
Posted in Budget - March 2012 | Leave a comment

Enveloping of High Value Residential Properties – some of the detail

As noted below, the Chancellor announced a new 15% SDLT charge on the acquisition of UK residential property by “non-natural persons” where the consideration exceeds £2 million.  The details published today explain that the charge applies to transactions which have an effective date (i.e. were completed or substantially performed) on or after 21 March 2012. [...]
Posted in Budget - March 2012, SDLT | 2 Comments

Support for innovative industries

Previously announced measures in relation to the R&D tax credit and the proposed new Patent Box have been confirmed. The Government intends to introduce an ‘above the line’ R&D tax credit in Finance Bill 2013 to encourage R&D activity by larger companies.  There will be a consultation on the detail but the Government has stated that it [...]
Posted in Budget - March 2012, Corporation Tax, Patent Box, R&D Tax Relief | Leave a comment

Stamp duty shock announcements and a CGT surprise

We were expecting a number of changes aimed at stamping out stamp duty land tax (SDLT) avoidance but the changes announced by the Chancellor have gone far further than was expected.  They include: 7% SDLT charge on the acquisition of residential properties over £2 million from tomorrow, 22 March 2012. 15% SDLT charge when residential properties of over £2 [...]
Posted in Budget - March 2012, SDLT | 1 Comment

Corporation tax rate cut again – 24% from 1 April 2012

In line with the Chancellor’s stated aim to make the UK tax system the “most competitive in the world” the rate of corporation tax will be cut to 24% from 1 April 2012.  It will be cut by a further 1% for each of the next two years to 22% from 1 April 2014.
Posted in Budget - March 2012, Corporation Tax | Leave a comment

SDLT reform for bulk residential purchases

Today’s Budget contains details of a new SDLT relief which will benefit purchasers of residential property who acquire more than one dwelling.  The relief will be introduced in Finance Bill 2011 with effect from Royal Assent. Where this relief is claimed the rate of SDLT will be determined by the mean consideration for the dwellings [...]
Posted in Budget - March 2011 | Tagged , | Leave a comment

Stealth tax?

The Government has announced that from April 2012 the measure of inflation used to calculate increases in NICs rate bands, the CGT annual exempt amount and the annual ISA subscription limit will be changed from the retail prices index (“RPI”) to the consumer prices index (“CPI”), and that the default indexation assumption for all direct taxes will [...]
Posted in Budget - March 2011, Budget Update | Tagged , , | Leave a comment

Income tax and NICs to become one ?

The Chancellor announced plans to consult on the merger of income tax and NICs on the basis that operating two completely different systems “imposes totally unnecessary costs and complexity on employers, and costs the taxpayer in the extra burden it places on HM Revenue & Customs”.   A consultation document will be published later this year setting [...]
Posted in Budget - March 2011 | Tagged , , | 2 Comments

Supporting innovation – next Patent Box consultation May 2011

As part of its programme to deliver a more competitive corporate tax regime and to support innovation in the UK, the Government has confirmed its previously stated intention to introduce the Patent Box, which is a 10% corporation tax regime for net profits derived from patents and patented products.   The regime is still intended to come into [...]
Posted in Budget - March 2011, Budget Update | Tagged , , | Leave a comment