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: Stephen Hignett, Tax Partner, Olswang
Non-domiciled individuals
Following consultation throughout the summer of 2011, and the publication of draft legislation in December 2011, legislation will be introduced in the Finance Bill 2012 (which will take effect from 6 April 2012) to make certain changes to the taxation of UK-resident non-UK domiciled individuals who elect to be taxed on the remittance basis. In [...]
Posted in Budget - March 2012 Leave a comment
Statutory residence test
In the last Budget the Government announced its intention to introduce a statutory residence test for individuals with effect from April 2012. However, in December 2011, following a public consultation over the summer of 2011, the Government announced that the statutory residence test would instead be enacted in Finance Bill 2013 and take effect in [...]
Posted in Budget - March 2012 Leave a comment
Come back please, Usain Bolt!
Some good news in the Budget for UK sport. There has been quite a storm in the press in the last year or two over the way in which HMRC calculates the income tax due when non resident entertainers perform in the UK. These rules are very broad and charge to tax not only performance [...]
Posted in Budget - March 2012 Leave a comment
Further gambling duty update
So what does it say in the fine print of the Budget Press Release about the changes to gambling duties? Not a huge amount, but here’s the gist of it: - Machine games duty (MGD) will come into force on 1 February 2013 (and, at the same time, AMLD will be abolished and gaming [...]
Posted in Budget - March 2012, Gambling 5 Comments
Comments on the new SDLT and CGT proposals for companies owning residential real estate
These changes certainly represent unwanted news for both non-UK resident individuals and UK resident but not UK domiciled individuals who often own high value real estate in central London through a structure which includes a corporate owner. However, the main reason that such individuals commonly utilise corporate entities is for reasons other than CGT and [...]
Posted in Budget - March 2012, Capital Gains Tax, SDLT Leave a comment
Changes to gambling duties
As expected, the Chancellor has announced that gaming machines will be moved into the VAT exemption for gambling and, at the same time, a new Machine Games Duty will be introduced (being a form of GPT for machines). The news is that the headline rate of the new duty will be set at 20%. More [...]
Gambling duties – no news is good news!
There’s precious little in the Budget concerning gambling duties. The way in which machines are taxed is due to change in 2012/13, with the banded licence fee regime of Amusement Machine Licence Duty (AMLD) being abolished and machine takings no longer being subject to standard rated VAT. Under the new regime – of “Machine Games [...]
Posted in Budget - March 2011, Budget Update Tagged AMLD, Gambling, Machine Games Duty Leave a comment
Residence and domicile
On balance, the Budget contains mostly good news for non-doms. Higher remittance basis charge for long term residents Non-doms who have been UK resident for 12 years or more will, from April 2012, pay an annual charge of £50,000 (up from £30,000) in order to be taxed on the remittance basis. Whilst this is obviously unwelcome, it is a relatively [...]
Posted in Budget - March 2011, Budget Update Tagged domicile, non-doms, remittance, residence Leave a comment
VAT and LVCR (the £18 rule) – “Big deal!”
We’ve all heard the reports of small CD retailers (and the like) going out of business due to LVCR (or “low value consignment relief”). This is the rule which exempts from VAT goods (such as CDs) imported into the UK from outside the EU with a value of £18 or less. Following the Budget, the threshold [...]
Posted in Budget - March 2011, Budget Update Tagged Low value consignment relief, VAT, £18 rule Leave a comment
IR35 / Personal Service Companies