Private client briefing for March 2017

The chancellor announces in the final Spring Budget a reduction in the dividend allowance, the abolition of class 2 NICs, a widening of the DTTP scheme and measures for promoters of tax avoidance schemes. In Davies, the FTT finds in favour of HMRC on the tax treatment of ‘cashless for cash’ share options. The trustees in RBC Trustees (CI) Ltd succeed in a rectification application but with a reminder that a mistake merely as to the tax consequences of executing a deed of appointment will not in itself constitute grounds for rectification. Finally, three new Spotlights are issued by HMRC in pursuit of disguised remuneration schemes.