UK General Tax Developments HMRC updates guidance on what constitutes “ordinary share capital” Following the decision by the First-tier Tribunal (FTT) in Warshaw V HMRC, reported in our UK tax blog earlier this month, HMRC has updated its guidance on what constitutes “ordinary share capital” for the purposes of most tax provisions using that term. As well as … Continue Reading
There has been another development on the tricky but important subject of whether the rights attaching to preference shares mean that they are or are not ordinary shares for entrepreneurs’ relief (and other tax) purposes. Recent cases have shown that share with no right to a dividend are ordinary shares. HMRC has published its view … Continue Reading
Welcome to the January 2019 edition of the UK Tax Round Up. With the political focus continuing to be dominated by Brexit, this month has been reasonably quiet on the UK tax front. There have nevertheless been some noteworthy developments. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Season’s greetings from Proskauer’s UK tax team and welcome to the December edition of the Tax Round Up. Following the Autumn Budget and draft Finance Bill last month, this month has been comparatively quiet with very few significant announcements. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the November edition of the Proskauer UK Tax Round Up. This month has seen a number of developments, both on the domestic and international tax fronts. We have set out a summary of some of the main points of interest. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
The UK Budget took place on 29th October. The Chancellor, Philip Hammond, took the opportunity to make a series of targeted changes to the UK’s tax system, some of which had already been announced, but several of which were new and surprising. We have summarized here of the most eye-catching changes that will be of … Continue Reading
Welcome to the October edition of the Proskauer UK Tax Round Up. It has been a reasonably busy month, with a number of interesting UK cases being reported as well as further clarity from the CJEU in relation to VAT. The Autumn Budget will be presented later today and the Finance Bill 2019 will be … Continue Reading
Welcome to the September edition of the Proskauer UK Tax Round Up. This month has seen a number of interesting tax cases and some clarity on the meaning of ordinary share capital. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the August edition of the Proskauer UK Tax Round Up. Not unexpectedly, August has been a quiet month with just a couple of interesting developments. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
The proposed amendment to entrepreneurs’ relief (“ER”) in Finance Bill 2019 is designed to address one of the outstanding issues with the current law when dilution of a company results in the loss of ER. Under the current rules, a shareholder who has held, for at least 12 months prior to disposal, at least 5% … Continue Reading
On 6 July 2018 the UK Finance Bill 2019 was published by the UK Government. The draft Finance Bill contains the details of the new regime on taxation of non-UK resident investors in UK real estate that had been proposed in a consultation by HMRC following the November 2017 Budget (see Proskauer Tax Talks blog … Continue Reading
Welcome to the July edition of the Proskauer UK Tax Round Up. It has been a busy month with both the draft Finance Bill 2018-19 being published and various interesting cases being reported. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the May edition of the Proskauer UK Tax Round Up. This month we saw Advocate Generals’ opinions in two European Court VAT cases with UK implications and welcome European Commission State Aid approval for EMI option schemes which had expired. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the June edition of the Proskauer UK Tax Round Up. The last month has been relatively quiet in terms of new announcements and developments. We expect more activity over the next few weeks as the draft Finance (No.3) Bill will be published on 6 July 2018. Please view this month’s issue of the … Continue Reading
Welcome to the April edition of the Proskauer UK Tax Round Up. This month saw changes to the taxation of termination payments and the UK’s adoption of the OECD Multilateral Instrument into its double tax treaties coming a step closer. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the March edition of the Proskauer UK Tax Round Up. As promised, the Spring Statement from the Chancellor focused on the economy and public finances without any major tax announcements. However, a few interesting consultation and position papers were published. We have summarised these below along with a handful of other developments since … Continue Reading
Welcome to the February edition of the Proskauer UK Tax Round Up. Although there have been no major developments since our last issue there have been several interesting cases published. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the January 2018 edition of the Proskauer UK Tax Round Up. This month has been fairly quiet from a tax perspective, which provides a welcome respite from the busy end to 2017. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the December 2017 edition of the Proskauer UK Tax Round Up. There have been many announcements and publications this month, largely a result of the Autumn Budget and publication of the Finance (No. 2) Bill 2017-19. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
The UK Government has announced in today’s Budget (22 November) that it is launching a consultation on extending the scope of UK tax on real estate. Currently, non-UK residents who are investors in UK land and buildings are outside the scope of UK tax on gains on commercial property. They pay income tax on the … Continue Reading
Welcome to the November 2017 edition of the Proskauer UK Tax Round Up. The past month has seen a major case on interest finalised before the Supreme Court as well as some interesting proposals for the simplifications of the laws on VAT. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the October 2017 edition of the Proskauer UK Tax Round Up. The past month has been a number of interesting case decisions among other developments. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Welcome to the September 2017 edition of the Proskauer UK Tax Round Up. Since our last edition, the Finance (No 2) Bill has been published and started its passage through the House of Commons, draft legislation for inclusion in next year’s Finance Bill has been published and the date for the first Autumn budget has … Continue Reading
The Upper Tribunal (Tax and Chancery Chamber), the UK’s second level tax appeal court, have just published their judgement in the McQuillan case, which considered whether shares with no right to dividends or any other profits are or are not “ordinary share capital” (OSC) for UK tax purposes. There are a number of UK tax … Continue Reading
