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 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 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
Background As mentioned in our July 2017 edition of UK Tax Round Up, the UK has enacted a new corporate criminal offence of failing to prevent the facilitation of tax evasion. The law comes into effect on 30th September 2017, and businesses should ensure that they have considered its impact before then. A risk assessment … Continue Reading
The summer break means that we are still waiting for the new Parliament’s drafts of the Customs, National Insurance Contributions and Finance (No 2) Bills discussed in the July 2017 edition although the timeline for the Finance (No 2) Bill has now been clarified. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
It has been another relatively quiet month from a tax perspective as we continue to wait for the Summer Finance Bill, the first Finance Bill of the new Parliament, to be published. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
Following the UK general election on 8 June 2017, at which Theresa May’s Conservative party won the largest number of seats but lost its overall majority, the Queen’s Speech setting out the now minority Conservative government’s legislative programme for the next two years was delivered on 21 June 2017 at the state opening of Parliament. … Continue Reading
This month has been quiet from a tax perspective as a number of significant tax measures planned for inclusion in the first Finance Act 2017 were put on hold until after the general election. We will report on their progress in future editions. Please view this month’s issue of the UK Tax Round Up.… Continue Reading
The previous month has been dominated by politics, with an announcement of a snap general election leading to postponement of many proposals in draft legislation. This month’s edition of the UK Tax Round Up discusses how certain provisions of the draft legislation could be impacted by the election, among other issues.… Continue Reading
After numerous UK tax changes affecting asset managers over the past few years – not least the wholesale re-vamping of the tax treatment of carried interest and other fund participations for investment fund managers – the UK government’s budget last week (8 March 2017) was a relatively uneventful affair for those in the investment management … Continue Reading
Many people will be familiar with the information gathering and reporting requirements the OECD’s Common Reporting Standard (“CRS”) places on financial institutions. The first exchanges of information between tax authorities will take place next year, with all CRS jurisdictions exchanging information by 2018. And we are now starting to see how tax authorities expect this … Continue Reading
The UK’s 2016 budget was announced on Wednesday 16 March 2016. Although we are waiting for detailed legislation for most of the tax-related announcements, below is a brief summary of some tax points which have caught our attention. Capital gains tax (CGT) rates for individuals have been reduced from 28% to 18% (for higher and … Continue Reading
With effect from 8th July, 2015, UK resident investment management executives will pay capital gains tax on all their carried interest returns from investment funds (with the rate currently set at 28% for higher and additional rate taxpayers). The overall rate may in many cases be higher, since items of income such as interest and … Continue Reading
