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)
Category: Budget – March 2011
Tackling tax avoidance
In June 2010, “Tax policy making: a new approach” was published by HMRC and the Treasury. This consultation paper set out the Government’s approach to maximising the prevention of avoidance. Following on from that paper, the Government has proposed a number of measures, and provided further explanation of the four categories of work that it [...]
Also posted in Budget - March 2011, Olswang Budget Blog Tagged anti-avoidance, GAAR, tax avoidance Leave a comment
A further boost for high tech Britain with improved R&D tax relief
The announcement that the SME scheme rate of R&D relief will increase to 200% from 1 April 2011 and 225% from 1 April 2012 will be welcomed by the technology and life science industries who incur significant research and development expenditure. It should also ensure that the UK becomes a more attractive jurisidiction in which to undertake [...]
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; [...]
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 [...]
Also posted in Budget - March 2011, Budget Update Tagged Low value consignment relief, VAT, £18 rule Leave a comment
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 [...]
A good day for high risk start ups?
We are delighted that the Government has recognised the need to encourage investment in high risk start up companies through proposed improvements to the EIS and VCT rules but the question is does it go far enough ? The proposed changes should be beneficial for the creative and technology industries for whom access to finance continues to be challenging. Whilst [...]
No more retrospective tax law changes?
Whilst the Government has not indicated that it will never introduce tax changes on a retrospective or retroactive basis, under the Protocol, changes to tax legislation where the change is effective from a date earlier than the date of announcement will be “wholly exceptional”. Such changes to tax law normally will be announced only by the Budget. Outside [...]
Entrepreneurs’ relief – £10 million lifetime limit
The Chancellor announced that the entrepreneurs’ relief lifetime limit will be doubled from £5 million to£10 million. This change must be positive for business but, as this is the only change to entrepreneurs’ relief, some will disappointed as there was some hope that the arbitrary requirement to hold 5% of ordinary share capital in qualifying companies would be removed to allow incentivisation of [...]
Residence and domicile