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Category Archives: UK Tax

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Latest on Abolition of Entrepreneurs’ Relief

There has been much talk recently about “review and reform” (or abolition) of entrepreneurs’ relief. This seems to have moved a step closer this week with Boris Johnson stating that the Treasury are “fulminating” against it on the basis that it made “staggeringly rich” people “even more staggeringly rich”. The debate about this was kicked … Continue Reading

Simplification of UK Partnership Tax Reporting for Investment Fund Partnerships

In the Finance Act 2018, the UK Government enacted a number of changes to the information required in partnership returns that raised the concern of undue and impracticable administrative burden being imposed on UK investment fund partnerships. The changes covered a number of areas, including requiring a UK partnership that had partnerships amongst its partners … Continue Reading

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise from avoidance, evasion or repeated insolvency and non-payment of tax debts or tax-related penalties of the company. The legislation is targeted at individuals … Continue Reading

Change to IR35 tax obligations from April 2020 for medium- and large-sized companies

New rules to be introduced from April 2020 will make certain companies who engage workers through intermediaries (the “client”) subject to: assessing whether the workers should be treated as employees of the company; and operating employment tax (PAYE and NICs) in respect of payments made to the workers or their intermediary. Currently these obligations rest … Continue Reading

UK Tax Round Up

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

Are fixed rate preference shares “ordinary share capital” for entrepreneurs’ relief – more or less certainty?

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

UK Budget – Some Key Changes

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

UK Finance Bill 2019 published – UK commercial property tax regime for non-resident investors to change, but some relief for trading businesses

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

UK Tax Round Up: March 2018

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
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