Jun 032016
 

Last year, the Government made some changes to the rules on entrepreneurs’ relief, aimed at individuals who use a corporate vehicle to conduct their business. Before the changes, it was possible for the individual’s personal company to trade through a joint venture or partnership and apply “look-through” rules to qualify for trading status. This was stopped, but now, following Budget 2016, the position is being restored in cases where the individual holds a 5% interest in the relevant joint venture or partnership.

However, there are quirks in the new rules. As we shall see, the position has not been restored exactly in the way that one might expect. We shall concentrate on the rules for joint ventures, but the rules for partnerships are similar and give rise to the same issues.

(This article can be downloaded in pdf format at Academia.edu)

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Property Tax: Why can’t corporate landlords deduct their finance costs in calculating their profits?

 Corporate Tax, Property Tax  Comments Off on Property Tax: Why can’t corporate landlords deduct their finance costs in calculating their profits?
Apr 152016
 

Did you know that a corporate landlord can’t deduct its borrowing costs when calculating the profits of its rental business? Don’t believe me? Well, it’s true. And in this article we are going to find out exactly why.

I must confess that I myself had always assumed that interest payments on loans taken out to fund the business were tax deductible. But I got a huge shock one day when I was doing a piece of research and my eyes strayed into another part of the legislation. But once I got over my shock, I realised what was really going on.

(This article can be downloaded in pdf format at Academia.edu)

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Apr 132016
 

A major political storm is brewing in Westminster as more revelations into the tax affairs of leading public figures have come to light.

It appears that many of these figures have salted away substantial sums of money in a trust structure that allows them to draw an income tax free, and with no capital gains tax to pay when they sell their investment. Furthermore, it looks as if the taxman is letting them get away with it.

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Apr 122016
 

Those of you who aren’t interested in Euro-law or compliance matters will probably be tempted to skip this article. While these are extremely important topics, I must confess, I too find substantive tax law more interesting. But instead of turning the page, I strongly suggest that you carry on reading. For these new rules aren’t confined to a single particular tax pigeonhole, but will affect a range of tax incentives such as the EIS and VCT Schemes.

In certain cases, failure to comply with the new rules may lead to a denial of the relevant tax break.

(This article can be downloaded in pdf format at Academia.edu)

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Mar 162016
 

Well, today is the big day. As usual, we have a dedicated Budget page from which I will try and give an orderly presentation of the links to the various documents.

I shouldn’t have to do this of course. HMRC – or the Inland Revenue – once did this on their own site. Some of you will remember that site. You know the one I mean. When HMRC used to give out information rather than hiding archiving it. Before the days that the IT crowd started interfering with upgrading the site.

Budget Day 16 March 2016 – where are the documents?

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Mar 092016
 

They are here of course.  Well, that’s where they say they’ll be. At the moment it’s just an empty page.

But don’t you believe it – just wait till the Big Day arrives, and once more, we’ll be taken on a merry-go-round the GOV.UK pages, trying to find whatever piece of paper that we’re so desperately trying to get hold of because some client desperately wants to know whether they’ve finally abolished entrepreneurs’ relief.

So who’s looking forward to this Budget? Are you? I’m not. I’m too busy recovering from the last one.

Feb 162016
 

It cannot have escaped most people in the UK that Google has just done a deal with HMRC, agreeing to pay a certain amount of money as a settlement for the tax that they are said to owe the UK Government. The Government immediately hailed this as a victory, but almost everyone else is very angry because it is too little, and because Google is a wicked multinational company that doesn’t pay its fair share.

I’m beginning to think it’s déjà vu all over again. And once again, as on all the other occasions when we hear about how a Google or a Starbucks or a Vodafone is dodging its taxes, I just pull a big woollen blanket over my ears and carry on with what I was doing. Continue reading »

Finance Bill 2016 – Corporate Tax, IP and Partnerships

 Corporate Tax, IP Tax  Comments Off on Finance Bill 2016 – Corporate Tax, IP and Partnerships
Jan 272016
 

In the last two Budgets, the Government did a lot of heavy tinkering with the rules on goodwill related intangibles. In the first Budget of 2015, they stopped tax relief when a company acquired such assets from a related party, and in the second, Summer Budget of 2015, they extended this treatment to unrelated parties. One would have expected the Big Bad Wolf to be satiated by now, but it seems not – Autumn Statement 2015 has given us yet another set of restrictions on intangibles related tax relief.

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Happy New Year for 2016

 Miscellaneous  Comments Off on Happy New Year for 2016
Jan 122016
 

I would like to wish all my readers, both old and new, a Happy New Year for 2016. I hope that your year goes well, and that you all get the things that you deserve the most (which is not the same as what you want!) Continue reading »