The insertion of a US holding company by way of a share-for-share exchange, whereby the shares in an existing UK company (“UKCo”) are transferred to a new US company (“USCo”) in exchange for shares issued by USCo, is commonly...more
Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more
In private equity secondary transactions, it is commonly assumed that UK stamp duty is not payable. However, in light of the latest HMRC consultation on modernising stamp duty on shares, the approach to dealing with stamp...more
Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more
Highlighting key tax points coming out of the recent economic update (8 July) delivered by the UK Government: Temporary reduction in stamp duty land tax (“SDLT”) on residential property purchases in England and Northern...more
In response to the COVID-19 crisis HMRC has updated its guidance on the process for getting documents stamped and paying the stamp duty, including that: Stock transfer forms should not be posted to the Stamp Office. Instead...more
On 25 March 2020, HMRC updated its stamp duty guidance to announce a temporary change in the way that it is dealing with stamp duty, as a result of measures to stop the spread of COVID-19...more
Here is a brief summary of the measures in the March 2020 Budget which are relevant to the Real Estate sector. Non-UK resident companies with UK property income – As previously announced, non-UK resident companies that...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2020 on 11 March 2020. The Budget was delivered against a backdrop that very few people could have anticipated at the commencement of the year....more
Finance Bill 2019-2020 - The FB19-20 was published on 11 July. The majority of the matters included have been announced previously with no surprise measures. The draft legislation is now open for consultation. We have...more
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...more
The time the UK allows a purchaser for filing a Stamp Duty Land Tax (SDLT) return and paying any tax due to HM Revenue and Customs is about to decrease substantially. Where the “effective date” of a transaction is on or after...more
General UK Tax Developments - CIOT responds to the draft profit fragmentation provisions in the Finance Bill 2019 - The Chartered Institute of Taxation (CIOT) has published its response to the profit fragmentation...more
On 19 August 2016, the UK Government published a new consultation paper together with draft legislation which will affect changes to the non-domiciles (“non-doms”) regime in the UK. The proposals will be legislated...more
Chancellor George Osborne delivered his fifth coalition Budget today. In a wide-ranging statement, there are a significant number of tax-focused proposals that will make changes across the U.K. tax system. Some of these...more
The Chancellor had previously warned that he would “not hesitate to move swiftly, without notice and retrospectively” to counter aggressive and widely marketed Stamp Duty Land Tax (SDLT) schemes. Last week, when announcing...more