Nov 232016
 

The Corporation Tax Annual is part of a collection of Core Tax Annuals published by Bloomsbury Professional. There are eight volumes in all, making a complete set. Apart from corporation tax, the annuals deal with: income tax, capital gains tax, national insurance contributions, stamp taxes, VAT, inheritance tax and trusts and estates.

This year, there’s another set of annuals to deal with the Scottish taxes. Because as you’re all aware, Scotland has recently been following its own tax map – Scotland can set its own tax rates and has its own set of stamp taxes called Land and Buildings Transaction Tax. And soon, Wales and Northern Ireland will follow suit. Creating a nightmare for tax practitioners. Continue reading »

Finance Bill 2016 – Entrepreneurs’ Relief and Joint Ventures

 CGT, Corporate Tax  Comments Off on Finance Bill 2016 – Entrepreneurs’ Relief and Joint Ventures
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)

Continue reading »

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)

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.

Continue reading »

Summer Budget 2015 – Goodwill Regained – but for how long?

 Corporate Tax, IP Tax  Comments Off on Summer Budget 2015 – Goodwill Regained – but for how long?
Aug 142015
 

In a previous article we saw how the Government spoilt everyone’s fun by abolishing corporate tax relief on goodwill when acquiring a business. But there may be a silver lining to our goodwill cloud, though how long this will last remains to be seen.

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

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Update – Will Investment Funds be taxed at the same 18% rate as Corporates?

 Authorised Investment Funds, Corporate Tax, Investment Tax  Comments Off on Update – Will Investment Funds be taxed at the same 18% rate as Corporates?
Aug 052015
 

I can’t believe it. I’ve received a response to my email to HMRC enquiring what will happen to the tax rate for retail investment funds when the corporate rates are coming down to 18%.

Someone thinks I’m important at last! (Now if only The Times Money section will admit their VCT error).

The answer is a nice straightforward – “They may be. Then again, they may not.” Continue reading »

Corporate Tax rates are coming down to 18% – will the investment funds in your pension still be taxed at 20%?

 Authorised Investment Funds, Corporate Tax, Investment Tax  Comments Off on Corporate Tax rates are coming down to 18% – will the investment funds in your pension still be taxed at 20%?
Jul 312015
 

For years, retail investment funds have been subject to corporation tax at a special rate of 20% – special, because for a long time, the main corporate rate was 30% or more. But recently, corporate rates have been gradually coming down, till at last, this summer we are told that the main rate will eventually go down to 18% by 2020.

But what about authorised investment funds? Are they to be included in the new bonanza for corporates? Or will they continue to be taxed at the same 20% rate?

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

Continue reading »

Jul 152015
 

8140678383_b981c48d95No, it’s not really goodbye. Goodwill hasn’t gone away, it’s still there all right. A company that acquires a business is still required to write down the value of the purchased goodwill in its accounts. But from 8 July 2015, it will no longer be able to deduct the amounts written off when calculating its taxable profits.

This isn’t great news. Not great news at all – it was actually hidden away towards the bottom of the list on the relevant GOV.UK webpage. I only found it easily because I’ve got into the habit of looking for those Budget measures to be effective immediately, so I can start writing my own Budget page.

So what does it all mean? And why do I find myself laughing? Continue reading »

Jul 102015
 

I recently attended a conference at the Said Business School in Oxford, “celebrating” Fifty Years of Corporation Tax in the UK. Yes, that’s right, fifty years have passed since a special tax was introduced for companies. No, it doesn’t mean they weren’t paying any tax before, they just paid a different tax – what that tax was called I couldn’t possibly tell you, since I wasn’t in practise at the time.

This was the first tax conference I’d been to for a very long time. The last time was in 2003 in London, one of those conferences organised for tax practitioners by IBC or whatever they call themselves these days. This conference was held in Oxford – the first time I’ve attended the Said Business School, which I’ve passed on a number of occasions, since I live locally, and sometimes go day tripping to the City of Spires. Continue reading »