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Olswang Analysis - June 2010
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Category: Olswang Budget Blog
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 [...]
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 [...]
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 [...]
Patent box confirmed
The Government has confirmed its plans, announced in the Pre-Budget Report (PBR) 2009, to introduce a reduced rate of corporation tax of 10% for income from patents from April 2013, in a bid to encourage more products being manufactured in the UK. The PBR 2009 stated that it would apply to patents granted after the Finance Bill [...]
Also posted in Budget - March 2010, Budget Update, Patent Box Tagged Intellectual Property, IP, Patent Box 1 Comment
SDLT partnership anti-avoidance
The press releases confirm that stamp duty land tax (SDLT) anti-avoidance legislation will be introduced in the Finance Bill 2010 “to target those who exploit the SDLT partnerships rules to reduce artificially the SDLT payable on some land transactions”. From the basic details which have been outlined in the press release, it seems that the existing general anti-avoidance [...]
REITs – stock dividends
One of the criticisms of the REIT regime has been the 90% distribution requirement, which restricts the ability of a REIT to preserve cash for reinvestment. So the Chancellor’s decision to allow the issue of stock dividends in lieu of cash is welcome - these dividends will now count towards the profit distribution requirement. There is no tax saving for shareholders, [...]
Game on !
After months of lobbying from the UK games industry, the Government has finally announced its intention to introduce games tax relief to support our highly successful and innovative games industry. Olswang has been heavily involved in this lobbying process and wrote a paper called “A tax relief for games” setting out how to adapt the existing film tax credit relief to [...]
Capital gains
Notwithstanding many forecasts to the contrary the Chancellor has decided not to change the main rate of capital gains tax. Indeed, he has decided to increase Entrepreneurs relief, from £1 million to £2 million. Far from accelerating sales it looks as if some taxpayers would have been better off by delay. Further details should be [...]
Also posted in Budget - March 2010, Budget Update, Capital Gains Tax Tagged Capital Gains Leave a comment
Bank Levy