ANALYSIS

Cutting edge analysis on tax issues.

We have, in recent years, seen significant changes to the taxation of UK real estate in the hands of non-UK persons. For example, FA 2016 brought offshore companies carrying on a trade of dealing in or developing UK land within the charge to...

Lisa Macpherson

FA 2019 Sch 1 is a rewrite and consolidation of TCGA 1992 Part 1. The real devil in the detail is FA 2019 Sch 2, which contains the administrative requirements for making non-resident capital gains tax (NRCGT) returns (and UK...

Constantine Christofi

Adam Craggs

FA 2019 ss 80 and 81 insert into TMA 1970 and IHTA 1984 extended time limits for assessing income tax, CGT and inheritance tax (IHT), where a loss of tax arises out of, or involves, an offshore matter or offshore transfer....

For a number of years, the UK government has been keen to get North Sea field interests into the hands of parties who will maximise the economic recovery from those assets.One of the stumbling blocks to such assets transferring is that the new owners...

FA 2019 Sch 4 introduces targeted rules to tax arrangements through which UK resident individuals (or in some cases companies) carrying on a business transfer a disproportionate part of their profits to offshore entities in low-tax jurisdictions and...

Mike Dalton

There were only a small number of changes to stamp taxes introduced by the Finance Act, but they are quite a mixed bunch. They range from a fundamental change to the SDLT return filing deadline, through a welcome relief for first-time buyers who are...

Stuart Walsh

In a response to the 2015 decision of the CJEU in Larentia + Minerva (Case C-108/14)), FA 2019 Sch 18 changes the UKs rules on VAT groups to allow individuals and partnerships to become members of VAT groups. The new rules do not come into...

David Rudling

FA 2019 Sch 17 creates a new VATA 1994 Sch 10B which provides for a new regime for the taxation of face value vouchers issued on or after 1 January 2019. It mirrors EU Council Directive (EU) 2016/1065, which came into effect on the same day and...

Andrew Hubbard

In a number of recent cases, the First-tier tribunal has concluded that a return submitted voluntarily without a notice to file having been issued is not a valid return for the purposes of TMA 1970 s 8. See for example, Patel Patel v HMRC...

Kate Ison

Jessica Hocking

Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner) examine the key findings and implications from two policy papers published at the time of the Spring Statement.

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