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:
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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)
Category: Budget Update
SDLT – anti-avoidance rules to come?
No substantive changes have been announced today in relation to stamp duty land tax. The Government has however announced that “it will examine whether further changes to the rules on stamp duty land tax on high value property transactions are needed to prevent avoidance in this area”. The Liberal Democrats had proposed a number of [...]
How will the Emergency Budget affect the gambling industry?
Although the Chancellor suggested that no rates of duty would increase, he mentioned specifically only those relating to alcohol, tobacco and vehicles. We will be checking the small print in the Treasury press releases to see whether any of the UK’s seven gambling duties are to be affected. The increase in the rate of VAT [...]
Video Games Tax Relief gets axed
After weeks of speculation, the Government has broken its silence on the topical issue of video games and decided to axe the relief announced by their predecessors. At a time when the UK needs to stimulate business in the UK this is very disappointing news. We are surprised that a relief aimed at keeping this growing and innovative industry in the UK was described as “poorly [...]
Also posted in Budget - June 2010, Video Games Tax Credit 1 Comment
The Coalition Programme – Summary Of Taxation Proposals
In the initial Coalition Agreement of 11 May 2010, the final Coalition Programme released on 20 May 2010 and the Queen’s Speech given on 25 May 2010 (as well as the recent speeches given by George Osborne) a number of initiatives and changes have been proposed by the Government in relation to the tax system, [...]
Posted in Budget Update Comments closed
Pensions after 2011 – some more detail but not the full picture
The Government has confirmed that tax relief restrictions on pension contributions for high earners will apply from next year for those with incomes of £150,000 or over. Essentially, tax relief on pension contributions will be restricted for those on “gross incomes” of £150,000 and over, gradually tapering down so that for those on incomes of [...]
Also posted in Budget - March 2010, Pensions Tax Relief Tagged high earners, Pensions Tax Relief, £150000 Leave a comment
Film
There was little of excitement in today’s Budget for the UK film industry. However, HMRC is continuing to target the UK film industry through the number of enquiries and litigation in relation to perceived film tax avoidance structures. Thus far, HMRC is not having much success. We were very pleased to see the recent Court of Appeal decisions in Halcyon and Microfusion, cases which the [...]
Also posted in Budget - March 2010, Film Tax Relief, Olswang Budget Blog Tagged Film Leave a comment
SDLT and partnerships – some further thoughts
Some clarity concerning the anti-avoidance measures may be starting to emerge. Existing opportunities arise because transactions involving partnerships are dealt with under schedule 15 FA 2003, which schedule provides a complete code. Mitigation is possible by ensuring that the appropriate degree of connection exists as between the vendor and one or more partners in the purchasing partnership, so that [...]
Bank Payroll Tax
It has been confirmed that legislation in Finance Bill 2010 will introduce the bank payroll tax (“BPT”). The Chancellor announced that BPT “has raised £2bn, more than twice as much as was forecast” and, although there was speculation that the tax would be extended, BPT will have effect only from 9 December 2009 until 5 [...]
Corporation tax – lower rates to come