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 »

Jan 182015
 

Updated January 2016

In the case of Drilling Global Consultant LLP v HMRC, a limited liability partnership (“LLP”) was denied the annual investment allowance on upgrading an aircraft on the basis that its members weren’t all individuals. The result is a straightforward application of the capital allowances legislation. However, the arguments put forward by the LLP are of some interest, as well as being totally wrong.

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

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Property Tax and the Lease Premium Rules – Why is the tenant’s tax relief spread over the lease?

 Property Tax  Comments Off on Property Tax and the Lease Premium Rules – Why is the tenant’s tax relief spread over the lease?
Nov 192014
 

When a landlord grants a tenant a short lease for a premium, part of the latter sum is treated as an income receipt in the hands of the landlord. The tenant is allowed to deduct this income element against his own revenue receipts, the deduction being spread over the length of the lease (we are assuming that the tenant is occupying the property for business purposes).

I know this latter fact because this is one of the topics that I learned about when I attended the courses that my employer sent me on, when I started my tax career. I also know this because I read about it in an article on buying and selling real estate which appeared in one of the various tax magazines.

That article even had the statutory reference for the tenant’s deduction, so that I could feel confident that it was a true statement. But until recently I didn’t have occasion to look too closely at what the legislation said. And when I did look, I found that the answer wasn’t as obvious as I had expected.

Continue reading »