HMRC

News & Analysis as of

Changes To The Taxation Of Termination Payments

Summary - The government has published its response to feedback received on its proposals to simplify the taxation of termination payments, expected to come into force in April 2018. The following table sets out...more

Proposed changes to UK lease taxation

HMRC published a discussion paper on 8 August 2016 setting out how the UK’s plant and machinery lease taxation rules might be changed in light of IFRS 16, the new accounting standard for leases. Responses to the paper...more

Blog: Share Incentives for Employees of Private UK Companies

Companies generally consider it a good idea for employees to be stakeholders in the business in which they work and believe share-based incentives offer the ability to reward, motivate and retain key staff. There are...more

Blog: A new UK corporate criminal offence: failure to prevent the facilitation of tax evasion

The UK’s tax authority, Her Majesty’s Revenue & Customs (HMRC), has just closed its consultation on a new corporate criminal offence: failure to take reasonable steps to prevent tax evasion....more

Pensions Round-Up: June 2016 (UK)

Welcome to the latest edition of Pensions Round-Up which provides an overview of developments in pension legislation, case law and regulatory guidance. In this edition we look at key developments from June 2016 including...more

NCA and HMRC to Lead Taskforce to Investigate the Panama Papers

From early 2015, 11.5 million documents belonging to a Panamanian law firm, Mossack Fonseca, were provided to a German newspaper, Süddeutsche Zeitung, who shared them with the International Consortium of Investigative...more

UK Financial Regulatory Developments - April 2016 #19

FCA decides to ban former LIBOR trader - FCA has published its Decision Notice concerning a former derivatives trader at UBS, Arif Hussein, banning him from performing any significant influence function relating to any...more

UK Government consults on UK VAT Grouping Rules

Summary - The UK tax authority (HM Revenue & Customs (HMRC)) is to formally consult on proposals for changes needed to the UK VAT grouping provisions. The consultation is as a result of European Court decisions which...more

UK Taxation Update for Investment Managers

The shifting sands of the taxation landscape for investment managers continues apace. Just when you perceive an oasis of stability on the horizon, it is revealed to be a mirage by the announcement of yet further changes....more

National Living Wage – bad news for business or a blessing in disguise?

When Chancellor George Osborne introduced the National Living Wage (NLW) last summer, he confidently asserted that this would help move the UK "to a higher wage, lower tax, lower welfare society". Despite his positive words...more

Clampdown on VAT avoidance on sales of goods through online marketplaces

The Chancellor has announced a package of measures to give HMRC stronger powers to collect VAT from overseas businesses who sell goods online to UK customers. Failure to pay VAT in these circumstances is estimated to have...more

Changes to salary sacrifice childcare vouchers

Employees can receive childcare vouchers either on top of their normal salary or by salary sacrifice. Under a salary sacrifice arrangement, an employee agrees to a variation to their contract terms, reducing their salary to...more

Budget Announcements: CRC Energy Efficiency Scheme to be Abolished and Climate Change Levy To Be Raised

It has been announced in today’s Budget that the CRC Energy Efficiency Scheme (CRC) will be abolished from 2019 and the Climate Change Levy (CCL) will be raised to compensate. The announcement comes following a...more

Discrimination and Childcare Vouchers

The UK Employment Appeal Tribunal (“EAT”) held on 9 March 2016 in Peninsula Business Services Ltd v Donaldson that it was not unlawfully discriminatory for an employer to suspend the payment of childcare vouchers during...more

Do you need to take action before the end of contracting-out?

The end of contracting-out and the introduction of the new single-tier State Pension on 6 April 2016 is now just over a month away and there are a number of issues that employers and trustees of schemes containing...more

New UK Withholding Tax Exemption For Qualifying Private Placements

On 1 January 2016, a new exemption from UK withholding tax for interest paid on “qualifying private placements” came into force. The conditions to the new exemption focus on various attributes that HMRC consider to be...more

Tax-efficient Pension Savings in the UK: Government Applies Further Restrictions

Employers may want to adjust compensation packages, and high-earners may want to revise their retirement savings strategies. In recent years, the UK government has reduced the lifetime and annual thresholds up to which...more

"No Gains, Just Pain: Increasingly Uncomfortable Taxation Environment for Private Equity Executives’ Compensation"

Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more

Qualifying Private Placement Exemption

The qualifying private placement exemption, which became available on 1 January 2016, makes interest on privately placed notes and/or bilateral loans exempt from United Kingdom withholding tax in certain circumstances where...more

New year, new exemption: The UK withholding tax exemption for privately placed debt

Just over a year since the Chancellor of the UK Exchequer George Osborne announced in his Autumn Statement 2014 the introduction of a UK withholding tax exemption for interest paid under private placements (a form of unlisted...more

Financial Services Quarterly Report - Fourth Quarter 2015: Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

The Private Placements Withholding Tax Exemption

The Finance Act 2015 introduced an exemption from a borrower’s obligation to withhold tax from interest payments arising on qualifying private placements. It was introduced to stimulate and grow the private placements market...more

HMRC consults on bank levy changes

HMRC and Treasury are consulting on changing the scope of the bank levy from a global balance sheet basis to a UK balance sheet basis. The changes would take effect from 2021. The proposal is that, from 2021, all banking...more

Further Change to the UK Taxation of Carried Interest

The UK Government, as anticipated, issued draft legislation on 9 December designed to establish clear rules as to when carried interest can qualify for favourable capital gains tax treatment. The draft legislation follows a...more

Change in the UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After...more

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