HMRC

News & Analysis as of

New Scotland Bill – tax implications

The UK Government has published draft legislation on devolving certain tax matters to Scotland (the Bill). It intends that the draft legislation should implement the terms of the devolution agreement made in November 2014...more

Summer Budget 2015––Carried Interest: Abolition of Base Cost Shift

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

UK Summer Budget 2015 – Key Issues for Asset Managers and Non-UK Domiciled Individuals

On 8th July 2015, the UK Government announced several changes to UK tax legislation that will affect those holding carried interest in fund structures which utilise at least one partnership (including a limited partnership),...more

The UK Summer Budget - Private Equity and Investment Management

The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

UK Summer Budget 2015: Osborne's 'Big Summer Budget' – the key measures impacting business

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

Tax Measures in the UK 2015 Summer Budget

The new tax announcements are designed to improve productivity and correct imbalances in the tax system. On 8 July, UK Chancellor of the Exchequer George Osborne made a number of announcements relating to the tax system...more

UK Summer Budget 2015 – Key Tax Measures

The Chancellor of the Exchequer’s first Budget of the new Parliament, delivered on 8 July 2015, will be remembered as a reforming Conservative budget, including significant changes to the United Kingdom’s welfare provisions...more

UK Supreme Court case of Anson v. HMRC [2015] UKSC 44

Delaware LLC held to be UK tax transparent - The UK Supreme Court has handed down its judgment on the final appeal in the Anson case, in which it treated a taxpayer's interest in a Delaware LLC as transparent for UK tax...more

Is It All Now Transparent? UK Supreme Court Case on Delaware LLCs Leaves Open Questions on Entity Classification for UK Tax...

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 44. Reversing the decisions of the Upper Tribunal...more

UK Employee Share Plans Tax Filing Deadline

In order to avoid penalties, companies should be sure to complete mandatory online registrations well in advance of the 6 July deadline. Companies which operate employee share plans in the UK are required to make a...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Enforcement – FCA Fines £13.2 Million for Transaction Reporting Failures - The FCA fined Merrill Lynch International (MLI) £13.2 million on 22 April 2015 for incorrectly reporting 35,034,810 transactions and failing to...more

UK FATCA -- Election dates extended in ARR for UK RNDs

The British Virgin Islands and the Cayman Islands have entered into agreements with the UK for automatic disclosure of information in respect of interests in financial accounts held by UK residents. Most UK residents are...more

Pensions News - April 2015

In This Issue: - Budget 2014 reforms - The Pensions Regulator - Legislation - Case Law - Public Service Pension Schemes - Other News - On the Horizon - Excerpt from...more

AML Bulletin - Spring 2015

In This Issue: * UK News & Enforcement Action: - HMRC releases AML and CTF supervision report 2013 – 2014 - HM Treasury High Risk Money Laundering List Updated - FCA Thematic Review Into AML And Sanctions...more

Diverted Profits Tax: counterbalancing the UK's "open for business" agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of...more

Upper Tribunal Decision in Samarkand and Proteus

The long-awaited Upper Tribunal Decision in the Samarkand and Proteus case has been published. The case relates to statutory sale and leaseback partnerships with partners claiming losses under the film acquisition relief...more

New reporting requirements for employment intermediaries

HM Revenue & Customs (HMRC) continues to strive to reduce the number of workers not subject to PAYE. It has added new reporting requirements for businesses that it considers to be ‘employment intermediaries’. Care is now...more

Investment Funds Update - Europe: Legal and regulatory updates for the funds industry from the key asset management centres and...

Tax: HMRC Publishes Filing Dates for New AIFM Mechanism for Partnership Deferred Remuneration Arrangements - The Finance Act 2014 introduced a provision intended to help partnerships (including LLPs) that are AIFM...more

Pensions News - March 2015

In This Issue: - Budget 2014 reforms - Budget 2015 - The Pensions Regulator - Legislation - DC Charges and Governance - Case Law - HMRC - Public Service Pension Schemes - Other News - On the...more

A Guide to the UK Disguised Investment Management Fee Rules

New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more

Pension News

In This Issue: - Budget Reforms - DC Charges and Governance - Department for Work and Pensions - Legislation - Public Service Pension Schemes - Other News - On the Horizon - Excerpt from...more

New Developments In The VAT Treatment Of Securitisation Servicing

HMRC are expected to consult on revisions to their published guidance to clarify the circumstances in which they will treat loan servicing in securitisation arrangements as exempt for VAT purposes....more

VAT recovery and pension schemes: Where are we now?

HMRC’s policy on reclaiming VAT on investment management and other costs remains under review in the light of two recent decisions from the Court of Justice of the European Union. The first of these cases, PPG...more

Pension News

Welcome to DLA Piper’s Pensions News publication in which we report on recent developments in pensions legislation, guidance and case law, as well as keeping you up to speed on what to look out for in the coming months. This...more

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