
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
Other Olswang Publications
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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:
Click here or on the image to download a printable PDF of all of our analysis:
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: Natasha Kaye, Tax Partner, Olswang
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 [...]
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 [...]
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 [...]
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 [...]




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