ANALYSIS

Cutting edge analysis on tax issues.

This years Act makes the following changes to the capital allowances regime:The annual investment allowance (AIA) limit is increased to 1m between 1 January 2019 and 31 December 2020.Enhanced capital allowances (ECA) are removed from...

Matt Stringer

FA 2019 contains two notable changes to UK taxation of controlled foreign companies (CFCs), both of which take effect from 1 January 2019.The current UK CFC rules were included in FA 2012, following a significant re-write of older provisions. The...

Lynnette Bober

While the UK remains a member of the EU, it has to abide by EU treaty provisions. In addition, depending on whether a deal is agreed, the UK may have to abide by EU law for some years to come. As such, FA 2019 s 22 and Sch 7 have been enacted in...

John Lindsay

Schedule 11 makes a number of changes to the corporate interest restriction legislation that is contained in TIOPA 2010 Part 10 and which took effect from 1 April 2017. Most of the changes made by Sch 11 have been made to ensure that the legislation...

Ross Robertson

FA 2019 makes several changes and additions to the diverted profits tax (DPT) legislation within FA 2015 Part 3.The DPT impacts multinational businesses where transactions between the UK and foreign companies are perceived to lack economic substance...

Susan Ball

While there were several changes covering employment taxes, two areas are becoming more prominent:changes to the conditions of HMRC scale rate payments; andchanges to the optional remuneration arrangements (OpRA) rules on company car versus...

This years Act introduced a number of changes relating to entrepreneurs relief (ER). While concerns that the relief might be abolished in its entirety to eliminate its estimated 2.7bn cost to the Treasury were ill founded, the...

Richard Cherrett

In 2017, the UK implemented a detailed set of hybrid mismatch rules to combat cross-border tax advantages arising from hybridity for example, the differing tax treatments of entities, transactions or instruments. The...

Pete Miller

One of the more interesting part of this years Finance Act, from my perspective, is that an anomaly that arose in FA 2011 has finally been fixed in FA 2019.Following a review of the impact of capital gains on companies after the 2010 Budget,...

David Porter

Schedule 14 of this years Finance Act impacts lessees accounting under IFRS 16 for periods of account starting on or after 1 January 2019. IFRS 16 brings operating leased assets onto the balance sheet of the lessee for the first time, and the...

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