Another EBT scheme fails the GAAR panel sniff test – immediate action may be required
As we all know by now, most EBT/EFRBS type arrangements don’t “work” in the sense they are not accepted to deliver the hoped for tax result. Cases such as Oco/Toughglaze and Rangers saw to that, Read more
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HMRC IR35: tips and pointers
We have previously discussed the planned extension of the Off Payroll Working rules to medium and large size employers in the private sector from 6 April 2021. This involves shifting the responsibility that currently exists under IR35 Read More
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Disguised Remuneration and the loan charge: Actions required by 30 September 2020
Following the Finance Act 2020 receiving Royal Assent, and HMRC publishing updated guidance on its settlement terms, users of EBTs, EFRBS and other disguised remuneration arrangements should note Read more
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IR35 extension to the private sector delayed but what will it mean for those affected?
The latest Finance Bill extended the “Off payroll working” rules (originally IR35) as they apply to public sector bodies to medium and large companies in the private sector. The start date has been put back to 6 April 2021, which is to be welcomed, but will those affected be ready for the change? Read More
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Non-Resident Landlord Companies – are you ready for the change to Corporation Tax?
The extension of corporation tax to companies resident outside the UK for tax purposes is a major change to the way Non-Resident Landlords (NRLs) are taxed in the UK. Corporation tax will be charged on rental profits arising from 6 April 2020 onwards. Read More
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Repayment of corporation tax based on expected future losses
In May the Government announced the extension of its Job Retention Scheme until at least mid-October 2020. In so doing, more than one million employers will continue to receive direct support from the Treasury which will meet 80% of furloughed employees’ salaries Read More
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Where angels fear to tread – HM Treasury Future Fund for high-growth companies
The devil is in the detail
The Future Fund, which is to launch in May, will provide loans of between £125,000 and £5 million, subject to matched funding from private investors. Read More
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COVID-19 and Property Taxation
In previous newsletters we have discussed the implications of the unfolding COVID-19 crisis for personal tax residence (link here) and business tax (link here). Read More
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COVID-19 and Business Tax
Restricted international mobility, plunging exchange rates and impending recession arising from the COVID-19 crisis throw up significant tax implications. Read More
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COVID-19 and counting days for UK statutory residence tests for 2019/20 and 2020/21- HMRC’s view
The legislation in the statutory residence test allows for some days to be ignored in applying certain of the statutory residence tests where the “exceptional circumstances” condition is met. Read More
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