Budget 2011 - In Britain to stay?

There has been much speculation as to how the special rules for taxing non-doms might change. On Budget Day we found out – at least for this parliament.

The good news for non-doms is that they will be able to remit income and/or capital gains tax free for the purpose of commercial investment in UK businesses. This effectively gives up to 50% tax relief on the amounts remitted. We await the outcome of consultation to establish what investments will qualify but in general this is good news for those who want to invest in the UK.

Outside the world of tax, there is further good news for individuals who want to settle in the UK. Only a week ago, the Border Agency also announced a relaxation of the immigration requirements to attract foreign investors and entrepreneurs to the UK. The changes mean that those with significant wealth to bring to the UK will be given a fast track to settlement in the UK. For example, those with £10 million to invest can settle in the UK after only 2 years. Previously, they would have had to wait at least 5 years to apply to settle in this country.

Of course, residence for tax purposes and residence for immigration purposes are not necessarily the same and have to be considered separately. Following a number of tax cases in relation to residence, the Government have finally announced a long-awaited statutory residence test and there will be consultation on this, too, over the summer with a view to implementation from April 2012.

The not-so-good news is that there is a proposed increase to the charge some non-doms need to pay in order to access the remittance basis. Currently, those non-doms who have been here for 7 out of the previous 9 tax years have had to pay an annual £30,000 charge in order to benefit from of the remittance basis. From April 2012, those who have lived in the UK for 12 years will have to pay £50,000 per year instead.

Finally, we have been promised some simplification of the technical rules on remittances but we must, once more, wait for further details to be released.

The big message is, though, that non-doms are welcome in Britain.

Lisa Spearman is a partner at Mercer & Hole. If you would like to discuss the contents of this post with Lisa you can call her on 020 7353 1597.


 

Budget 2011 - Tax Plus Special

Chancellor George Osborne unveiled his Budget on Wednesday 23 March 2011. In response, the team at Mercer & Hole has published a Special Edition of Tax Plus which analyses the issues raised. It can be accessed by clicking here.

A new Tax Rates and Allowances card has also been produced in line with the 2011 Budget announcement and can be accessed here

 

The TAX family: their story continues

In March 2010 we first met Mercer & Hole ‘clients’, Tom, Andrew and Xena, of the ‘TAX’ family.
Things have moved on for the family over the last three months and in this emergency Budget special edition of Tax Plus, we take a look at how the Budget, which included both well heralded
announcements and some surprises too, impacts them and their businesses.

 

Emergency Budget 2010 - Financial Planning Budget Highlights

By George, was it as bad as I thought it might be? No... and there's even the odd bit to be optimistic about.

Pensions

Well it's all change again in the world of pensions with the third set of changes in as many months, on top of simplification introduced back in April 2006. The anti-forestalling measures for 2009/10 and 2010/11 introduced previously remain unchanged, however, complexity reigns and taking advice should be the default position.

For those high earners building pension funds, it's worth noting there will be consultation over the next few months to review the changes due in April 2011. The pensions industry has been fairly vocal with regards to 'doing away' with higher rate relief for those earning over £130,000. The likelihood is that the current annual allowance will be reduced from £255,000 to between £30,000 to £45,000.

For some clients this is an opportunity to keep contributing to pensions, where previously we anticipated this year was 'going to be it' in terms of new payments. If you are a director/shareholder of a business and in a position to make large employer contributions (up to £255,000 - deductible expense), I strongly advise you to explore your options in the coming months, to either rule in or rule out a large contribution while you have the chance.

The detail is to be confirmed but if you are caught by the £130,000 earnings limit keep your ears and eyes open.

Changes are afoot for those who are about to take benefits, this could prove to be quite interesting, although again, the devil is going to be in the detail and we don't know what that is yet. Up until yesterday when you reached the age of 75, you must have made a decision about taking your pension benefits - whether that was buying an annuity, or taking income via alternatively secured pension income. Under the new proposals this compulsion is being reviewed and new rules will come into effect 6 April 2011. Please note there is no compulsion to purchase an annuity, however you have to take income at the age of 75 and this is the most common option for doing that.

As an interim measure, those who reach the age of 75 on or after 22 June 2010 will not have to buy an annuity or otherwise secure a pension income until the age of 77. However, they will still have to take their lump sum and become entitled to income drawdown immediately before their 75th birthday.

Until the changes come into effect, a tax charge of 35% will be imposed on lump sum death benefits paid, if an individual dies with income drawdown on or after 22 June 2010 aged 75 or over. This will replace the charges applicable on lump sum death benefits in alternatively secured pensions, which previously could amount to 82% in total, although you would be lucky to get a provider to pay them in the first place as it's an unauthorised payment. This means the option of a lump sum payment is now possible, this certainly broadens out who can receive the benefits now up to age 75 , which has got to be a good thing!

For individuals with money purchase arrangements that reach the age of 75 on or after 22 June 2010, and have not yet purchased an annuity, the strict minimum and maximum limits associated with alternatively secured pension will now apply from their 77th birthday and not their 75th birthday.

The details are to be announced shortly when the consultation finishes.

The good news as far as the state pension is concerned, is this will now increase in line with earnings. This is also seen as a way of reducing the impact of means testing on savings.

ISAs

The ISA allowance will be increased in line with RPI from April 2011, rounded to the nearest £120. This is not massively exciting but every little bit helps. More important is that you try and use your allowance consistently.

Long term, stocks and shares have got to be the better bet, whereas cash is good for liquidity. The best rate for cash ISA's at the moment is Santander.

Child Trust Funds (CTFs)

Further government contributions are to cease from August 2010 for those aged seven and new CTFs will cease from Jan 2011. For those with existing accounts the legislation around contributions remains the same. Generally, we like Children's Mutual for CTFs.

Capital Gain Tax (CGT)

After much speculation the rate will go up from from 18% to 28% for higher rate tax payers. Thankfully everyone gets to keep their annual allowance of £10,100. The rate change came into effect last night at midnight and there are no retrospective charges for those who have made disposals between 6 April to 22 June.

Great news for Entrepreneurs' relief, where the limit goes from £2 million to £5 million.

EIS & VCT

From our perspective there is nothing in the Budget that will change our stance on EIS & VCTs, we were concerned that the emergency Budget would upset the opportunity for clients to invest in lower risk VCTs and EISs, again thankfully there doesn't appear to be anything that will change this moving forward. Moreover, these types of investments can, in the right circumstances, be an alternative vehicle to pensions for those caught by anti forestalling.

Anne McClean is a senior Financial Adviser at Nightingale Associates. The views given in this blog are personal to the author.  If you would like to discuss the contents of this post with Anne you can call her on 020 7353 1597.

M&H LLP trading as Nightingale Associates is authorised and regulated by the Financial Services Authority.
 

Emergency Budget 2010 - Deferring pension

Good news for those nearing age 75 and not wanting to take their pension benefits - there will be an end to the effective requirement to use a pension fund to buy an annuity by age 75 from 2011/2012. The government will consult shortly on the detail of the changes being introduced.
 

Emergency Budget 2010 - Non Dom taxation to be reviewed

The Chancellor has announced that the Government will review the taxation of non-domiciled individuals. This reiterates a statement made previously in the Coalition Agreement.

No further details as to when the review might take place have been released.
 

Emergency Budget 2010 - Tax rates

The Chancellor has announced a number of changes to the personal allowance, the basic rate limit for income tax and National Insurance thresholds, all to be effective from 2011/2012.

The personal allowance for those under the age of 65 will increase by £1,000 from £6,475 to £7,475.

The threshold for basic rate tax will be reduced. The effect of this will be that higher rate taxpayers will not benefit from the increase in personal allowance. We do not yet know what the basic rate threshold will be but the Chancellor has said that the detail will be released in September once the RPI is known.

The threshold at which employers will start to pay employers Class 1 NICs will be increased by an extra £21 per week above indexation.

At the stroke of midnight tonight, some changes will be introduced to capital gains tax:

The rate of capital gains tax for higher rate taxpayers will increase to 28% from the current 18%.

The rate of CGT for gains that qualify for entrepreneurs relief will remain at 10% and there will be an increase in the lifetime limit on gains that can qualify from £2m to £5m.

The individual's capital gains annual exemption will remain frozen at the 2010/11 level of £10,100.
 

Emergency Budget 2010 - Trust CGT changes

Although some trustees are technically only liable to basic rates of income tax, it has been announced that the CGT rate for all trustees will be 28% for gains on or after 23 June 2010 (except where entrepreneurs' relief applies). This is also the case for personal representatives of deceased persons.
 

Emergency Budget 2010 - Furnished holiday lettings survive another year

The last Government announced last year that the special treatment for taxing Furnished Holiday Lettings would be abolished from April 2010 having extended it temporarily to properties in Europe. Today’s Budget documents have confirmed that that the special rules have survived for another year and that the Government will consult about changing the rules from April 2011.

Emergency Budget 2010 - VAT

The main changes announced today are:

  • As expected the standard rate of VAT will increase to 20% on 4 January 2011. Anti-forestalling legislation has been announced to prevent any widescale planning.
  • There are no changes to the current zero rates. The flat rate scheme percentages will be increased in line with the increase to the standard rate of VAT.
  • The standard rate of Insurance Premium Tax will increase by 1% to 6%. The higher rate will increase by 2.5% to 20%.
  • Previously announced changes to the zero rating of certain types of aircraft.
  • Previously announced changes to the place of supply of certain types of natural gas and heating/cooling systems.
  • Previously announced changes to the use of the Lennartz principle for certain types of asset used for business/private use.
  • Previously announced changes to the VAT exemption for certain public postal services provided by the Royal Mail with effect from 31 January 2011. Stamped mail remains exempt so private individuals should be largely unaffected.

Emergency Budget 2010 - further tax measures

Mercer & Hole can report the following tax measures:

  • VAT - increased to 20% from 4 January 2011(zero rating remains for food and children's clothes).
  • Council Tax - the Government will assist local councils freeze council tax for one year (from 2011).
  • Capital Gains Tax - 
    • Basic rate tax payers will pay 18%
    • From midnight tonight higher rate tax payers will pay 28%
    • The entrepreneurs' rate will be extended to the first £5 million earned.
  • Income tax - the £6,475 tax free allowance will be increased to £7,475 in April 2011 (higher rate tax payers will not benefit from this change).
  • There were no new duties on tobacco, alcohol and fuel.

 

Emergency Budget 2010 - Measures announced so far...

  • Tax credits will be targeted at those who need their support most.
    • There will be a reduction in payments to families with income greater than £40,000.
  • Child benefits
    • Child benefits will be frozen for the next three years.
  • The public sector has been targeted for measures
    • A two year pay freeze has been announced.
    • Those at the top of the public sector organisations will be paid no more than 20 times their lowest paid colleagues.

Emergency Budget 2010

Mercer & Hole's expert team has just taken their seats to listen to the Chancellor, George Osborne's first Budget.

He tells us it will be, "tough, but also fair".

Mercer & Hole will blog throughout the afternoon and issue our summary analysis on 'Tax Plus' tomorrow.

Non-dom advice - Lisa Spearman featured in 'Taxation' magazine

Lisa Spearman, Private Client Partner at Mercer & Hole and leader of our non-domiciliary focus group has been featured in today's edition of 'Taxation' magazine.  Lisa has written the article 'Not such a safe haven?' on non-dom issues, offering advice on how best to deal with 2010 tax returns.

Key tax deadlines (June - August 2010)

Below are some key upcoming tax deadlines that you may need to consider. These dates cover the period June – August 2010.

19 June 2010 - PAYE and NIC due for the month ended 5th June 2010. Submit Construction Industry Scheme return for the month ended 5th June 2010.

5 July 2010 - Final date for agreement of 2009/2010 PAYE Settlement Agreements.

6 July 2010 - Final submission date for returns of expenses and benefits (forms P11D and P9D) for the year ended 5th April 2010.  Relevant employees to be provided with copies of forms P11D and P9D.

6 July 2010 - Submission date for annual share scheme returns (form 42) for the year ended 5th April 2010.

14 July 2010 - Deadline for submission of forms CT61 and payment of any associated income tax for the quarter ended 30th June 2010.

19 July 2010 - PAYE and NIC due for the month ended 5th July 2010.  Quarterly PAYE and NIC due for the quarter ended 5th July 2010 for qualifying small employers. Due date for payment of Class 1A NIC arising on relevant benefits in kind for the year ended 5th April 2010. Submit Construction Industry Scheme return for the month ended 5th July 2010.

31 July 2010 - Second payment on account due in respect of 2009/2010 personal tax. Second penalty of £100 applied where 2009 self-assessment tax return has not yet been submitted. Second 5% surcharge applied where 2008/2009 tax has not been settled in full by this date.

2 August 2010 - Submission date for forms P46 (Car) for changes during the quarter ended 5th July 2010 to car or fuel benefits provided to employees.

19 August 2010 - PAYE and NIC due for the month ended 5th August 2010. Submit Construction Industry Scheme return for the month ended 5th August 2010.

Another key date that everyone is waiting for with anticipation is Tuesday 22 June 2010.  Chancellor George Osborne has confirmed that the new Conservative-Liberal Democrat coalition government's emergency budget will be unveiled on this date

We will be blogging on SME Plus Blog and Tax Plus Blog on Budget day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Budget 2010 - Chancellor George Osborne sets UK emergency budget for Tuesday 22 June 2010

Chancellor George Osborne has confirmed that the new Conservative-Liberal Democrat coalition government's emergency budget will be unveiled on Tuesday 22 June 2010.  Mr Osborne confirmed the date at a briefing with his Lib Dem deputy David Laws, the Treasury Chief Secretary.  

Mr Osborne said that the new coalition government will start "significantly reducing" the country's record deficit, with the emergency budget being used to detail the UK government's plans to cut public spending. 

Mr Osborne also stated that the new government will review all decisions on spending made in 2010 by the previous Labour Party government.  

We will be blogging on SME Plus Blog and Tax Plus Blog on Budget day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Tax planning opportunities in uncertain times

Cathy Corns author on our sister blog SME Plus has highlighted some tax policies which have been announced following the formation of the Conservative-led coalition government - the key issues are highlighted below.  

I will also be posting further blog posts as the detail becomes clearer.  In the meantime, if you would like to discuss these and other tax planning opportunities available to you, please do not hesitate to contact me

Tax planning opportunities in uncertain times

We are living in interesting and uncertain times. We do now know who is governing Britain and that we will have a Budget within the next 50 days. There is a lot of speculation, but tax is going to change.

Some measures announced in the 2009 Pre Budget and the (first) 2010 Budget have not yet hit the statute books, so there is uncertainty over which will be retained. The coalition agreement makes specific mention of some tax policies which may affect you.

Capital Gains Tax

This tax is about to change again with CGT rates being aligned with income tax rates on non-business assets. The end result could be significantly more tax for higher earners, but with, possibly, extended entrepreneurs’ relief. Where this relief is not available, now may be a good time to look at realising gains to take advantage of the current rate of 18%. It is important though to consider all angles balancing earlier tax payment with the benefit of a lower rate of tax. It is not clear whether the change will be introduced from the date of the emergency budget or next 6 April.

Pension contributions

There are already rules to restrict the amount of higher rate relief that anyone earning over £130,000 can claim on pension contributions. The Lib Dem manifesto proposed the removal of all higher rate relief on pension contributions. I do not know when or if this measure will be introduced, but if you planned on making contributions in the current tax year, now may be a good time to do this.

Other changes

The inheritance tax threshold is not now going to be increased significantly in the short term at least but there will be an increase in personal allowances. These points will have a bearing on how your family organises its financial affairs in the round.
 

Emergency Budget - but when?

Before the election the Conservatives promised that if they came to power there would be an emergency Budget within 50 days of an election . Today’s publication of the initial agreement between the Lib Dems and Conservatives, which will be followed by full coalition agreement, refers to such a Budget being within 50 days of signing any agreement. It is not clear if the clock starts with this initial agreement or with the full agreement when it appears. The Budget may not be as soon as we may think.

Also mentioned in the initial agreement is an indication that capital gains tax will rise to 'rates similar or close to those applied to income'. There is no indication from what date this may take effect but there is a reference to generous reliefs for business gains so we wait to see what form that will take.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597.

 

Budget 2010 - introducing the 'TAX' family

We have taken a different approach this year in considering the Chancellor's Budget announcement.  With this edition of Mercer & Hole's Tax Plus we have highlighted how some of the changes will impact on the 'TAX' family. 

Please contact me if you'd like to discuss any of the issues experienced by Tom, Andrew and Xena.

David Mansell is a partner at Mercer & Hole. If you would like to discuss the contents of this post with David you can call him on 01908 605552.

 

 

Budget 2010 - Penalties for offshore tax evaders

In addition to signing information exchange agreements with Antigua, Belize and Dominica, the Government has announced details of penalties for offshore tax evaders who do not make use of its so called 'amnesties' and come forward voluntarily.

In extreme cases the new penalty could be as much as 200% of the tax found to be due.

Budget 2010 - Pension contributions

The Chancellor has confirmed that new legislation, effective from 6 April 2011, will deny tax relief above the basic rate on pension contributions made by or on behalf of high income individuals.

The definition of high income is complicated and can mean either income of £150,000 or more, or income above £130,000 which, together with the value of employer’s pension contributions, exceeds £150,000.
 

Budget 2010 - ISAs

In his March 2009 Budget, the Chancellor announced a phased increase in the annual limit for ISAs, to £10,200.

This year’s Budget has included a provision to increase the ISA limit in line with inflation.

At current interest rates, though, it is hard to get too excited about being able to earn interest tax free on the extra £200 or so that might be available to invest in an ISA.

 

Budget 2010 - Stamp duty land tax change

During his Budget speech the Chancellor referred to an exemption of £250,000 for first time buyers. Having had a chance to review the press releases from HMRC we can provide a little more detail.

We had wondered how 'first time buyer' would be defined but it appears that the relief – which is only applicable for completions between 25 March 2010 and 25 March 2012 – will be given where 'the purchaser or all the purchasers' have not previously acquired a residential property. This is a somewhat unusual wording and it will be interesting to see if it is replicated in the actual legislation. Bearing in mind the effective date there will be some frantic reviews of contracts in solicitors offices across the country to determine the rate of SDLT payable.
 

Budget 2010 - tax information exchange

The chancellor has just announced he is about to sign tax information exchange with Dominica, Grenada and Belize. 

These agreements, he says, will be signed within days.

Budget 2010 - stamp duty

Darling tells us nine out of ten first time buyers will no longer pay stamp duty - as he has doubled the stamp duty payment threshold to £250,000 for first time buyers from midnight tonight.

Budget 2010 - a new approach to close company apportionments?

As Budget Day approaches, there has been speculation that the Chancellor is thinking about reintroducing some form of apportionment for close companies. In my opinion, an additional charge on dividends and other sources of investment income would be a much more effective way of dissuading owner managers from their present low salary high dividend regime.

In 1989, the then Conservative Government under Margaret Thatcher abolished the so-called close company apportionment rules which had been around since the 1920s. These provisions were intended to ensure that, where the directors of a successful family company decided not to distribute a substantial part of their post-tax trading and investment profits, they were deemed to have done so, subject to the retention of a reasonable sum for the working capital requirements of the business.

Given that the Chancellor of the Exchequer, Nigel Lawson, had recently harmonised income tax and capital gains tax rates at a maximum of 40%, it was considered that a measure designed to ensure that taxpayers should not benefit from a lower (or nil) rate on capital gains when the money could have been distributed as more highly taxed income in the form of a salary or dividend was now redundant.

In recent months, there have been rumours emanating from the Treasury that the present Chancellor is considering the possibility of re-enacting this former legislation. Presumably, the thinking is that, with effect from 6 April 2010, a high income individual will be taxed at up to 50% on his salary or 36.1% on his dividends, but that he only faces a capital gains tax charge of 18% (or sometimes 10%) on the disposal of his shares. Although it seems almost certain that capital gains tax rates will have to rise in the next year because of the gap between the top income tax and capital gains tax rates, the Government would probably wish to retain the present modest charge for those who qualify for entrepreneurs’ relief.

Accordingly, a tax scenario which encourages the retention of profits in owner-managed businesses – which is presently the case – is likely to be stopped. And one way of doing this might be to introduce a Mark II version of the close company apportionment regime.

Another consideration is that, with the impending introduction of higher rates of income tax, many existing unincorporated businesses will be turning themselves into limited companies in order to try and shelter profits at lower rates of tax than would be possible had they remained sole traders or partnerships. In other words, there will be a rush to incorporate not dissimilar to that which occurred in the early 2000s so that taxpayers can enjoy the advantage of extracting business profits via dividends more tax-efficiently than would otherwise be possible.

My own view is that the reinstatement of an apportionment procedure for close companies would have little or no effect on this latter situation other than perhaps forcing some business owners to distribute more profits than they were otherwise minded to do. Nor would it deal satisfactorily with the problem of the disparity between income tax and capital gains tax rates.

Although I do not personally like the idea (nor would many of my clients!), there is no doubt in my own mind that the most effective approach to discouraging owner-managed companies from pursuing the low salary high dividend routine which has been widely practised in the past is to introduce an additional levy on dividends and other forms of unearned income similar to the investment income surcharge which was abolished by the Finance Act 1984. A charge of, say, 15% on investment incomes above a specified threshold would almost certainly put a stop to tax planning of this sort.

This year's budget will be held on 24 March 2010. Commentary from Robert Jamieson, partner with Mercer & Hole and past President of the Chartered Institute of Taxation.

The views given in this blog are personal to the author, if you would like to discuss the contents of this post with Robert you can contact him at robertjamieson@mercerhole.co.uk or call 020 7353 1597.

We will be blogging on Tax Plus Blog andSME Plus Blog on Budget day. If you do not already subscribe to our blogs click here for Tax Plus Blog or here for SME Plus Blog to ensure you get our comment and analysis as and when it happens.
 

Pre-Budget Report 2009 - offshore accounts 200% penalties

Buried in one of the consultative documents that accompanied the Pre-Budget Report are proposals to charge penalties of up to 200% in respect of offshore bank accounts. This is a clear message from the Government that those with undisclosed tax liabilities should consider taking advantage of either the New Disclosure Opportunity or the Liechtenstein Disclosure Facility.

Consideration to a disclosure must be given to this now as one of the deadlines for telling HMRC that you intend making a disclosure is 4 January 2010. Further details can be found here.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597.

 

Pre-Budget Report 2009

Until this morning, in common with many of my colleagues, I was anticipating a comprehensive Pre-Budget Report which would set out Labour's stall in advance of the General Election next year. We were let down. The opportunity which Darling and the Labour Party had to establish the fiscal foundations for a potential fourth term has not been taken.

I had foreseen an increase in capital gains tax and changes to the main inheritance tax reliefs, but this did not happen.

Darling and Labour have played safe so as not to alienate the electorate.

What we have instead is a reduction in bingo duty and a tax on bankers' bonuses which may well prove ineffective and not make the desired contribution to our debt reduction. It has been a wasted opportunity.

Commentary from Robert Jamieson, partner with Mercer & Hole and past President of the Chartered Institute of Taxation.

The views given in this blog are personal to the author, if you would like to discuss the contents of this post with Robert you can contact him at robertjamieson@mercerhole.co.uk or call 020 7353 1597.

Pre-Budget Report 2009 - furnished holiday lets

The Chancellor has confirmed that the furnished holiday lettings rules will be withdrawn from 2010/11.

This means that a furnished holiday let will be treated as any other property business. Some of the tax consequences of this will include the following issues:

  • Losses incurred before 6 April 2010 that have not been relieved at that date will be treated as losses from a property business. These will then only be available to set against future profits of the property business as will any future losses.
  • Capital allowances will not be available for expenditure incurred on or after 6 April 2010 on plant and machinery for use within the let property.
  • The business is no longer a trade for capital gains purposes which will result in the potential loss of some valuable capital gains reliefs.
  • From 6 April 2010 income from letting furnished holiday accommodation will not be relevant UK earnings for pension relief purposes. 

Liz Cuthbertson is a partner at Mercer & Hole. The views given in this blog are personal to the author, if you would like to discuss the contents of this post with Liz you can contact her at lizcuthbertson@mercerhole.co.uk or call 020 7353 1597.

Pre-Budget Report 2009 - national insurance contributions

It had already been announced that there would be a half percent increase in National Insurance Contributions (NIC) from next April. Today’s Pre-Budget Report has announced that there will be a further half percent increase from April 2011. This means that from April 2011 the main rate for employees will be 12% and for the self-employed will be 9%. The rate of employer contributions will be 13.8%.

To compensate lower earners the starting threshold will be raised by £570.

Costs are going up more steeply than otherwise expected from April 2011.  The rates for the self-employed, employees and employers will all rise by 1% (previously expected to be at 0.5%).  This will mean an effective highest rate of tax of 52%

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - bank payroll tax

The Chancellor has announced in his Pre-Budget Report the expected measures to claw-back some of the large bankers’ bonuses for the tax payer.  The key details are as follows:

  • Legislation in Finance Bill 2010 will introduce a new bank payroll tax. This will be set at 50%.
  • It will be payable by a bank, on the amount of a bonus to which a banking employee is entitled, to the extent that the bonus exceeds £25,000.
  • A bank will also be liable to the bank payroll tax where the bonus entitlement arises in respect of services performed for the bank regardless of who awards the bonus.
  • The bank payroll tax will have effect from the time of the announcement on 9 December 2009 until 5 April 2010 for all discretionary and contractual bonus awards.
  • There is an exception for contractual bonus entitlements where the payer has no discretion as to the amount of the bonus because of a contractual obligation existing at the time of the Chancellor’s announcement.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - key points for private clients

The Chancellor has just sat down after presenting his 2009 Pre-Budget Report. We are awaiting the details being released on the Treasury website but the key points from his speech for private clients appear to be:

  • VAT will return to 17.5% on 1 January 2010
  • Stamp Duty holiday will end on 1 January
  • The time to pay scheme will continue for as long as needed
  • State pensions will rise by 2.5% from next April. Child benefit will also rise
  • A new boiler scrapage scheme for 125,000 households plus extra energy efficiency help
  • 50p tax on landlines to finance superfast broadband
  • 50% one off levy on bankers’ bonuses over £25,000 paid by the bank in addition to the tax paid by the employee
  • Freezing of Inheritance Tax Nil Rate band at £325,000
  • Freezing higher rate tax threshold
  • Anti avoidance measures following on from the information received from offshore banks
  • National Insurance starting threshold raised.

As is invariably the case there will be more important changes buried in the detail of the documentation. More information will be posted during the afternoon.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - just announced

The Chancellor has just announced that the inheritance tax threshold will be frozen at £325,000 until 2011.

Pre-Budget Report 2009 - pre-budget news

The Chancellor announces that a one off 50% supertax will be imposesd on bankers bonuses over £25,000.

Pre-Budget Report 2009 - just in...

The Chancellor tells us he is determined to support growth, predicting 1% growth in 2010 and 3.5% in 2011 and 2012.
 

Pre-Budget Report 2009 - news just announced

The Chancellor has just announced that the increase in the corporate tax rate has been deferred.  The 2010 tax rate will remain unchanged for small businesses.
 
 

Pre-Budget Report 2009 - PBR VAT news...

Chancellor Alistair Darling confirms that the VAT rate will return to 17.5% on the 1 January 2010 as anticipated.

Pre-Budget Report 2009 - bankers' bonuses the race is on

As mentioned in my earlier post it is expected that  large bonuses paid to bankers will be hit by today’s Pre-Budget Report.

The Times today are reporting that the race is on to amend bankers contracts and definitions in one way or another to escape whatever the Chancellor has in store.

We should know later today!

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - Northern Rock restructuring

Ahead of tomorrow’s Pre-Budget Report the Treasury has announced the restructuring of Northern Rock.

This is a timely reminder for those who held shares in the company that it may be possible to make a claim for the loss to set against other capital gains. Full details can be found on the HMRC website.

A similar situation arises for shareholders in Bradford & Bingley.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - bankers' bonuses to be hit?

It is been widely reported that bonuses paid to bankers are going to be hit in the Pre-Budget Report. As expected this has not been favourable received in the City.

It is unclear whether the Chancellor will propose a windfall tax on the banks or impose a higher rate tax charge on the bankers themselves – 60% has been mentioned. There will be practical difficulties in this latter approach – how do you define a banker?

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - do we need a Pre-Budget Report?

With all the speculation about the contents of Alastair Darling’s Pre-Budget Report (PBR), The Guardian is questioning the purpose of the PBR.

The paper reminds us that the PBR is an invention of New Labour and, particularly this year, is unnecessary. Given the forthcoming general election it probably only a matter of weeks before we have the 2010 Budget itself.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - many more to pay 40% tax?

The online version of The Daily Mail is predicting that many more people will be paying tax at the higher rate of 40% following the Pre-Budget Report. This will be achieved says the paper by freezing the level of personal tax allowances and not increasing the threshold at which the 40% rate starts.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - countdown to Chancellor Alistair Darling's Pre-Budget Report 2009

All eyes will be on Chancellor Alistair Darling in the House of Commons as he delivers his Pre-Budget Report 2009 at 12.30pm on Wednesday 9 December 2009.  The Pre-Budget Report comes as Britain struggles to emerge from recession and a General Election nears.

Stay in touch with our blogs after the Chancellor’s speech to find out the views of Mercer & Hole’s experts.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Lisa Spearman is a partner at Mercer & Hole. If you would like to discuss the contents of this post with Lisa you can call her on 020 7353 1597. 

Pre-Budget Report 2009 - Capital Gains Tax

It has been thought for some time that the rate of Capital Gains Tax (CGT) must increase to reduce the difference between it and the top rates of income tax. It was – and perhaps is – more a question of when than if. However, rumours are now flying that the rate of capital gains tax will go up with effect from the pre-budget report rather than the more usual 6 April. It would be rare although not entirely unheard of for a direct tax rate to increase during a fiscal year.

Clearly these are only rumours and we won’t know until the Chancellor’s speech on 9 December but if the 18% rate is important to you and you are in a position to do so you may wish to ensure that any capital gains tax transactions go through before 8 December. 

Stay in touch with our blogs during and after the Chancellor’s speech to find out what is actually announced.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Lisa Spearman is a partner at Mercer & Hole. If you would like to discuss the contents of this post with Lisa you can call her on 020 7353 1597. 

Pre-Budget Report 2009 - Tories set date for next year's (second) Budget

Even before the Chancellor’s Pre-Budget Report 2009 on 9 December the Conservative Party has indicated that they will have an 'emergency' Budget within fifty days of winning the general election next year.

Highlights of their proposals are:

  • a reduction in corporation tax to 25% (20% small companies)
  • increasing the stamp duty land tax threshold to £250,000
  • raising the transferable IHT nil rate band to £1million
  • a simple annual levy on all non-domiciles who want to avoid paying tax on their offshore income, in return for a promise not to change their tax regime for a Parliament.

It remains to be seen whether the Pre-Budget Report picks up on any of these ideas.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - Equitable liability saved - announcement in Pre-Budget Report?

Earlier this year HM Revenue & Customs (HMRC) announced that from April 2010 it would not be possible to claim the concessionary relief under the concept of 'Equitable Liability'. Essentially this was a way that HMRC was able to take a common sense and equitable view regarding the collection of a tax charge which although technically correct was clearly inequitable with the circumstances of the case. 

For example, a taxpayer may have ignored their tax position for years prompting estimated assessments by HMRC which became final and conclusive and valid for collection. When the taxpayer eventually addressed the problem the calculation of the tax due showed a much reduced position. In cases such as this HMRC was able to dispense with collection of the incorrect tax. Many in the tax profession objected to this and a campaign was spearheaded by the Chartered Institute of Taxation.

The CIOT has now heard from HMRC that they will be legislating 'at the earliest opportunity' to retain the practice. Perhaps there will be a formal announcement in the Pre-Budget Report on 9 December.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day. If you do not already subscribe to our blogs click here  for SME Plus Blog or here  for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Barry Hallam is a senior manager at Mercer & Hole. If you would like to discuss the contents of this post with Barry you can call him on 020 7353 1597. 

Pre-Budget Report 2009 - Chancellor's statement announced for Wednesday 9 December 2009

Chancellor Alistair Darling has confirmed that he will make his Pre-Budget Report statement on Wednesday 9 December 2009. We will be providing full analysis of Pre-Budget Report announcements on the day.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Lisa Spearman is a partner at Mercer & Hole. If you would like to discuss the contents of this post with Lisa you can call her on 020 7353 1597. 

Pre-Budget Report 2009 prediction

Although I think the 2009 Pre-Budget Report will not contain any shockers ahead of the General Election next year, I do feel that the tax take has to be increased somehow and this could lead to 'tweaks'. My own 2009 Pre-Budget Report prediction could be a change to the tax rule on 'flipping second homes' to mitigate Capital Gains Tax (CGT). This rule was widely publicised in the press earlier this year, following the criticism of MPs and their expenses, but actually is available to everyone with two or more homes and not just MPs!

Broadly speaking, a main residence (sometimes referred to as a Principle Private Residence) is CGT-free on a disposal provided the property was not purchased for the sole reason of making a profit and the dwelling was an individual's only or main residence throughout the period of ownership. Exemption also extends to gardens and grounds of up to half an hectare. The last 36 months are also always exempt. All fine so far but what happens where you have two or more main residences? The rules allow you to secure at least the last 36 months of any gain tax-free by flipping your main residence election to your second home for 1 month. You lose the benefit of 1 month of relief on one property but gain 37 months relief on another. This can represent a real tax saving.

If another residence is acquired, you have an opportunity to make an election for which property you wish to be covered for which periods otherwise the Revenue will choose for you. The election must be made within two years of the date the new situation arose and if one house is replaced then a new two year period begins. You must actually reside in both properties, for some time at least, and any period of ownership not elected as the main residence will be chargeable to CGT. There are also rules relating to the fact that a husband and wife, or civil partnership, can only have one main residence between them.

Please get in touch if you would like to know more about whether you can take advantage of these rules.

We will be blogging on SME Plus Blog and Tax Plus Blog on Pre-Budget Report day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Helen Mckie is a partner at Mercer & Hole. The views given in this blog are personal to the author, if you would like to discuss the contents of this post with Helen you can call her on 01727 869141.

Government moves position, slightly, on pension contributions

This year’s Budget proposed changes to the regime for tax relief on pension contributions. Essentially the proposal are that from 2011 higher rate tax relief will not be available to those with income over £150,000. To prevent a rush of people making large contributions before 2011 the Budget also proposed some anti-forestalling measures. These effectively capped the amount on which you could get higher rate relief to £20,000 unless you were already making regular contributions of more than that. 

One of the problems with this was that 'regular' meant contributions being paid quarterly or more frequently. As a result many, such as the self employed, who paid annual contributions stood to lose out. It seems that the Government has listened to the arguments and moved their position a little. The Finance Bill has now been amended so that, for infrequent contributions (ie less than quarterly), an average can be taken over the last three tax years subject to a cap of £30,000 instead of £20,000.

The Financial Secretary to the Treasury (Stephen Timms) said in the Parliamentary debate that he would be consulting with the pensions industry about introducing regulations to be more flexible in respect of those who had set up new pension arrangements on or just before Budget day and those who change pension providers and carry forward exactly the same pension arrangements.

It is expected that the Finance Bill will receive Royal Assent later this month.

Barry Hallam is a tax adviser and a Senior Manager at Mercer & Hole. The views given in this blog are personal to the author.

Budget 2009 - Furnished holiday lets - bad news and (a little) good news

Today’s Budget saw the publication over a hundred Budget notes, press pelease and other documents. One of these supplementary documents relates to the taxation of Furnished Holiday Lettings (FHL).

Currently, let properties in the UK, which fulfil the conditions, attract a beneficial tax treatment which means that the profits are counted as earnings for pension purposes and losses can be offset against other income.

The Government believes that the fact that this treatment is given to UK properties may not be compliant with European Law and so have decided that this should be repealed with effect from 2010/2011.

The good news is that the beneficial treatment should be extended to properties within the European Economic Area (EEA) until it is repealed. This means that that it is possible to submit amended tax returns and claim refunds in some cases.

  • Returns that are still within the normal time limit for amendment can be made within that time limit.
  • HMRC will also accept late amendments to personal tax returns for 2006/2007 and corporation tax returns for periods ending after 31 December 2006.

The deadline for making a late amendment is 31 July 2009.

Comment on this blog in the space provided below. Barry Hallam is a Senior Tax Manager at Mercer & Hole. 

Budget 2009 - Remittance basis...minor amendments

Following the significant changes to the taxation of non domiciled UK residents in last year’s Finance Act, today’s Budget note introduces some minor changes to the rules – and they are minor.

The most helpful is the extension of the exemptions (such as the personal use exemption) to assets purchased with foreign employment income and capital gains as well as relevant foreign income (interest dividends etc). Under the existing rules if a non dom bought an asset, such as a watch, for £1,500 out of foreign bank interest and brought it to the UK it would not be a taxable remittance, but if the watch had been bought with employment income or capital gains it would be taxable. With back dated effect (to 6 April 2008) there is no distinction between the type of income used to purchase the asset.

The Budget note also makes it clear that those individuals who are entitled to the remittance basis without a claim (such as those with less than £2,000 unremitted income or gains) will be deemed to have made a claim unless they 'opt-out' by notifying HM Revenue & Customs (HMRC). The number of individuals affected by this has also been extended to include those who make no remittances and have less than £100 of UK income. Previously if they had as little as a penny of UK income there was a requirement to claim the remittance basis by submitting a tax return.

There is some useful clarification on the interaction of the remittance basis and the settlements legislation and the availability of the £30,000 remittance basis charge to cover the tax credit on Gift Aid donations. There is also a change which relates to domiciled individuals who are not ordinarily resident in the UK who can also take advantage of the remittance basis. There is a relaxation to the requirement to submit a tax return for a UK resident employee who also has overseas employment income which is taxed overseas – provided that the individual has no more than £10,000 such income and less than £100 taxed overseas bank interest. 

In addition there is the previously announced statement of practice relating to transfers from offshore bank accounts that contains predominantly income relating to one employment contract.

HMRC have spotted two areas of potential abuse in the new rules. There is an anti-avoidance measure which defines the meaning of a 'participator' in the context of 'relevant persons'. In addition there is clarification of the rules for determining the value of an asset remitted which forms part of a larger set such as a series of linked artworks or a stamp collection.

All these changes have little real effect on the extremely complex rules introduced last year, although may avoid some of the more absurd scenarios that could have arisen.

Comment on this blog in the space provided below. Barry Hallam is a Senior Tax Manager at Mercer & Hole. 

Budget 2009 - VAT

It was a fairly uneventful VAT budget.

The Chancellor confirmed that the standard rate of VAT will revert back to 17.5% on 1 January 2010 as previously announced. Draft “anti forestalling” legislation has already been published and will be introduced in the Finance Act 2009 to prevent certain exempt businesses from planning to benefit from the rate increase.

There was speculation beforehand that the standard rate of VAT would increase to at least 18.5% and/or that the Chancellor would make use of new powers to extend the reduced rates of VAT but neither of these has happened.

Other VAT changes announced are:

  • The annual VAT registration threshold has been increased from £67,000 to £68,000. The annual threshold for deregistration has been increased from £65,000 to £66,000.
  • Revised fuel scale charges will apply to VAT returns on or after 1 May 2009.
  • VAT exemption will apply to gaming participation fees (bingo and other games of chance) with effect from 27 April 2009.
  • The rate of bingo duty will increase to 22% for any accounting period beginning on or after 27 April 2009.
  • Other miscellaneous changes to the rules for bingo and games of chance.
  • A package of changes to harmonise cross border supplies of goods and services and to reduce fraud, will be introduced on 1 January 2010 as part of an EU wide exercise. The UK has announced new rules in relation to EC Sales Lists for goods and services, overseas VAT refunds and the time and place of supply of certain cross border services.  
  • A reduced VAT rate of 5% will apply to bases for child car seats.
  • A minor simplification of the option to tax 'permission' rules where previous exempt supplies have been made.

Comment on this blog in the space provided below, or visit my profile for details of how to contact me.

Jane Stacey is a VAT Manager at Mercer & Hole.

Budget 2009 - Tax rates

Income tax increase

Currently income is taxable at either the basic rate of 20% on taxable income up to £37,400 and the higher rate of 40% applies to taxable income over that level.

Today’s budget has announced an additional higher rate of income tax of 50%, effective from 2010/11 for individuals with taxable income above £150,000.

Not only is this higher than the 45% tax rate initially announced in the 2008 pre Budget report but it will come into effect one tax year earlier than was expected.

The increase affects all income and therefore dividends otherwise taxable at the new 50% will be taxable at the new rate of 42.5%. The rate increases apply also to income of trusts and therefore the trust tax rate will increase to 50% and trust dividend rate will be 42.5%.

Loss of personal allowance

The basic personal allowance which provides an amount of tax free income will be gradually eliminated where a person’s total ‘adjusted net income’ is more than £100,000 by reducing the allowance by £1 for every £2 that the income limit is exceeded. Therefore, if the adjusted net income is £105,000, this exceeds the £100,000 limit by £5,000 and £2,500 of personal allowance would be lost.  

Comment on this blog in the space provided below. Barry Hallam is a Senior Tax Manager at Mercer & Hole. 

Budget 2009 - Budget statement...what is in store?

With less than a week until Chancellor Alastair Darling’s second Budget statement the speculation as to what may be announced on Wednesday 22 April 2009 is mounting.

Political  commentators such as www.politics.co.uk suggest that on one hand it should be a neutral Budget, but on the other hand spending is now part of the Government’s DNA. The British Retail Consortium (BRC), is reported in The Telegraph as saying that, “the high street is in need of some retail therapy”.

The Times reports that, “the Budget will make or break renewable energy” and the BBC is giving its own predictions here.

From a tax perspective much has already been announced in respect of the current tax year, but there may be changes announced for later years. Those dealing with the taxation of non-domiciled UK residents would welcome some simplification of the horrendously complex new rule introduced in Mr Darling’s first Budget last year. 

As usual, we will just have to wait and see! 

We will of course be blogging on SME Plus Blog and Tax Plus Blog, providing analysis on the key highlights next Wednesday.    

If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens. 

Non Doms - further guidance issued

HMRC have now published the promised detailed guidance on the taxation of Non Domiciled UK Residents and the Remittance Basis following the changes in last year’s Finance Act 2008. The guidance can be found on the HMRC Website and runs to over 400 pages. It is slightly disconcerting to note, from the introduction to one of the documents, that….

“….extra examples will be added to illustrate the working of the rules in less straightforward circumstances.”

So, we’ve just got the simple stuff for now!

It is expected that there will be some amendments to the rules announced in the forthcoming Budget.

We will be blogging on Tax Plus Blog and SME Plus Blog on Budget day.  If you do not already subscribe to our blogs click here for Tax Plus Blog or here for SME Plus Blog to ensure you get our comment and analysis as and when it happens.

Non Doms to have their tax affairs centralised - be prepared for a challenge

In advance of this year’s Budget which is expected to make some changes to the complex new rules for Non Domiciled UK Resident individuals (Non Doms), HM Revenue & Customs (HMRC) have announced that most individuals who pay the £30,000 Remittance Basis Charge will be transferred to a specialist office in Nottingham.

HMRC have also announced that they will no longer process Forms DOM1 (withdrawn) or P86 (to be replaced without the domicile questions) which are designed to provide a “ruling” on an individual’s domicile status. In future it is entirely up to an individual to decide their own domicile status when submitting their Self Assessment tax return and HMRC will be able to challenge this via the normal enquiry process. It appears that HMRC may be looking closely at individuals who have lived in the UK for a number of years but still claim to be a Non Dom even though HMRC gave a “ruling” previously. Their website states:

“For example if an individual had advised HMRC on their arrival in England a decade or so ago that they planned to leave the UK after five years but had since married, had a family and decided to make England their permanent home then they will have adopted a domicile of choice within the UK.”

They have also stated that even where a claim for the remittance basis has not been challenged for a particular year

“…..it does not mean HMRC necessarily accepts the individual’s domicile is outside the UK and does not prevent HMRC from later opening an enquiry to consider the domicile status of the individual in relation to that, or any earlier year. “

It is now more important than ever that adequate disclosure is made on the Self Assessment Tax Return to ensure a fighting chance against any challenge by HMRC.

HMRC have promised more detailed guidance “soon” – watch this space

We will be blogging on SME Plus Blog and Tax Plus Blog on Budget day.  If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Budget 2009

The Chancellor will make his Budget statement on Wednesday 22 April 2009.  We will be providing analysis of Budget announcements on the day.
 

Pre-Budget Report 2008

The Chancellor delivered his Pre-Budget Report on 24th November 2008. Our Partners and Managers posted a number of blogs in relation to the 2008 Budget announcement – on both SME Plus blog and Tax Plus blog.

For concise, up-to-date and easy to digest Pre-Budget information please find below a list of the respective blogs posted: 

SME Plus 

Pre-Budget Report 2008 - VAT

Pre-Budget Report 2008 - Plant and machinery leasing

Pre-Budget Report 2008 - Income tax...relief for trading losses

Pre-Budget Report 2008 - Tax relief for business expenditure on cars

Pre-Budget Report 2008 - Corporation tax...small companies rate

Pre-Budget Report 2008 - Corporation tax...tax relief for trading losses

Pre-Budget Report 2008 - Empty property relief

Pre-Budget Report 2008 - Taxation of foreign profits

Pre-Budget Report 2008 - HMRC Business Payment Support

Tax Plus 

Pre-Budget Report 2008 - Non doms update

Pre-Budget Report 2008 - Income Shifting Rules...the dog that didn't bark!

Pre-Budget Report 2008 - Top rate of income tax to be increased to 45%

Pre-Budget Report 2008 - National Insurance to be increased

Pre-Budget Report 2008 - Consultation documents

Pre-Budget Report 2008 - VAT

Pre-Budget Report 2008 - Compensation for the loss of 10% band made permanent

Pre-Budget Report 2008 - Tax rate for trusts to be increased

Pre-Budget Report 2008 - Pension tax telief...freeze on limits

Pre-Budget Report 2008 - Changes to trusts...trust Darling!

Pre-Budget Report 2008 - Penalties for late tax returns

To receive our blogs direct to your inbox visit http://www.mercerhole.co.uk/news, click on the blog of your interest and follow a few simple subscription directions.

Pre-Budget Report 2008 - Penalties for late tax returns

One of the many consultation documents that accompanied today’s Pre Budget report has indicated that HM Revenue & Customs would like to reform the penalty regime for the late submission of Self Assessment tax returns. Currently the £100 fine for filing a tax return late can be mitigated by paying sufficient tax by the due date. HMRC see this regime as largely ineffective.

The Revenue want to separate the obligation to submit a tax return from the obligation to pay the tax. One proposal is that there should be a fixed penalty arising the day after the filing date followed by daily penalties for continued delay (after three months). If the return remains outstanding there would a further penalty linked to the amount of tax due (up to 100%!).

Separately, the Revenue would be able to charge the usual interest for paying the tax late but also penal interest set at a percentage of the tax outstanding one, six and twelve months after the due date.

Expect changes in the 2009 Budget.
 

Pre-Budget Report 2008 - Changes to trusts...trust Darling!

Alastair Darling has announced increases to the dividend trust rate, and the trust rate of tax, effective from 6 April 2011.  These tax rates apply to income within discretionary settlements.  After the quite radical inheritance tax changes made by the government two years ago to trusts, it feels that they are once again taking the opportunity to have a further dig! 
 
Trusts are taxed as entities in their own right.  Thus under current rules, the trustees of a discretionary trust are liable to a 40% tax rate on any non-dividend income in excess of the standard-rate band.  From 6 April 2011, this increases to 45%.  Dividend income in excess of the standard rate band is presently taxed at 32.5% with a notional 10% tax credit.  This means the trustees effectively pay tax at a rate of 25% on the net dividend they receive.  Under current rules, on a net dividend paid to the trustees of £900, they will be liable for a further £225 in tax.  From 6 April 2011, this increases to £275. 

 

Pre-Budget Report 2008 - Pension Tax Relief...freeze on limits

Today’s Pre Budget Report contains the news that both the lifetime and annual allowances for pension schemes will be frozen from April 2011.

The lifetime allowance is due to be increased to £1.8 Million for 2010/20011 having being introduced in 2006/2007 at £1.5 Million. The annual allowance is due to reach £255,000 (up from £215,000 in 2006/2007)

The 2010/2011 limits will now remain until at least 2015/2016 without increase. It remains to e seen whether it will be possible to obtain pension relief at the new top rate of 45% after April 2011.
 

Pre-Budget Report 2008 - Tax rate for trusts to be increased

Hidden in the detail of today’s Pre Budget report is the news that, from April 2011 the tax rate applicable to trusts will be increased from 40% to 45% and the dividend rate for Trusts will be increased from 32.5% to 37.5%.

It is unclear whether a beneficiary who is only liable to basic rate or the “lower” 40% will be entitled to full credit for the tax paid by the trustees
 

Pre-Budget Report 2008 - Compensation for the loss of 10% band made permanent

Alistair Darling, in his second Pre Budget Report, has announced that the measures introduced in September as compensation for the removal of the 10% tax rate will be made permanent.

Initially the compensation, given by means of an, over inflation, increase in personal allowances of £600 was to last for only one year. It has now been announced that the increase will be permanent and in fact will be increased by a further £130 from next April. The basic personal allowance will be £6,475.

The point at which higher rate tax becomes payable is also increased by more than inflation (£800) to £37,400.

However, it is not all good news – from April 2010, those who have income of over £100,000, will have the personal allowances gradually restricted so that only basic rate relief is obtained and if the income exceeds £140,000 the allowances will be further restricted until extinguished.

As mentioned elsewhere, from April 2011 those with income over £150,000 will be liable at a top rate of 45%
 

Pre-Budget Report 2008 - VAT

As widely reported, the PBR today has confirmed that the standard rate of VAT will be cut to 15% with effect from 1 December 2008. (The new VAT fraction to be applied to VAT inclusive prices will be 3/23).

This means that standard rated supplies of goods and services made after this date will attract the new rate of VAT. Supplies at the zero or reduced rates and exempt supplies are not affected. The new rate will remain in place for 13 months till 1 January 2010, when it will rise again to 17.5%. (Anti- forestalling legislation will be brought in to prevent planning around the subsequent rate increase).

For sales spanning 1 December, special tax point rules mean that businesses can choose to charge VAT at the new rate on goods removed and services performed after the rate change, even if payment has already been received or VAT invoices issued. In those cases, credit notes will have to be issued to correct the VAT overcharged.

Special rules will apply to retailers, those providing continuous supplies of services (e.g construction industry) and other special schemes (second hand dealers etc). Detailed guidance on how to deal with the change is available on HMRC’s website.

The reduction in the standard rate will also amend the rates applied under the Flat Rate Scheme for small businesses. The revised percentages are published on HMRC’s website.

Other VAT and duty changes announced are;

  • Increase in threshold for Bespoke Retail Schemes with effect from 1 April 2009.
  • Simplification of the entry and exit rules for VAT Flat Rate Scheme with effect
    from 1 April 2009.
  • Payment arrangements for those having difficulties paying VAT bills via the “Business Payment Support Service”.
  • Increases in fuel/alcohol and tobacco duty.

The Chancellor has urged retailers to pass on the rate cut “as quickly as possible”. In reality, businesses may choose not to pass on the cut. They are unlikely to welcome it as it will cost them to implement changes to prices /accounting and point of sale systems. In the retail sector, where prices are already being heavily discounted, it is hard to see that a further 2.5% cut will have much of an impact on sales turnover.

Pre-Budget Report 2008 - Consultation documents...

There are 8 Consultation documents issued alongside the PBR documents which are to a greater or lesser degree related to the new powers and penalties regime which comes in from 5 April 2009. The documents refer to the proposed new customers charter (reference the previous taxpayers charter of the 1990s) and there is also particular attention paid to ensuring that returns are filed and tax is paid on time…slightly at odds with the 2 pages of FAQs on the HMRC website offering support to distressed businesses. We will review the consultation documents and respond to them in detail as necessary.

Pre-Budget Report 2008 - National Insurance to be increased

Alongside proposed increases in income tax the Chancellor has announced increases in National Insurance Contributions (NIC) will be increased by 0.5% across the board from April 2011.

This means that employers’ contributions will be increased to 13.3% and the main rates for employees and the self employed will be increased to 11.5% and 8% respectively. The additional rate for those who earn in excess of the upper earnings limit will also be increased by 0.5% to 1.5%

This is part of a package of proposed tax increases to help fund the short term measures announced elsewhere in his report.
 

Pre-Budget Report 2008 - Top rate of income tax to be increased to 45%

Chancellor Alistair Darling has announced in his Pre-Budget Report that the top rate of income tax is to be increased to 45% - but not until April 2011 and only on income over £150,000. This applies to income other than dividend income which will be taxed at 37.5% (up from 32.5%)

This is part of a package of proposed tax increases to help fund the short term measures announced elsewhere in his report.
 

Pre-Budget Report 2008 - Income Shifting Rules...the dog that didn't bark...!

One of the Press notices confirms that the rules on income shifting will NOT now be introduced in Finance Act 2009 despite their deferral from the 2008 Bill. The income shifting rules had been proposed as a method of dealing with the Arctic Systems type situation where a lower rate paying spouse benefits from the earnings of a higher earning spouse. The matter is being kept under review which – it is to be hoped – is code for being forgotten about….

Pre-Budget Report 2008 - Non doms update

Not all Bad News:

Interestingly, the withdrawal of personal allowances for those with income over £140,000 means that non domiciliaries claiming the remittance basis now have a bit less to lose – they will be in the same position as a high income UK domiciliary and with careful management, the impact of the withdrawal of the annual exempt amount can be kept to a minimum.

Pre-Budget Report 2008 - The Speculation Mounts!

With less than a week until Alastair Darling’s second Pre Budget Report (PBR) the speculation as to what may be announce on Monday 24 November is mounting.

Many commentators such as The Daily Mail and The Daily Telegraph are suggesting that the much heralded “tax cuts” will be geared to toward poorer families my boosting tax credits payments. This is echoed by The Sun and The Mirror . Whether the tax credits system is up to the task of putting extra cash in people’s pockets before Christmas is open to question.

The Guardian has David Cameron counselling The Chancellor against tax cuts and stating that Gordon Brown doesn’t “listen to his own lectures”. The Times has reported a call for VAT to be cut to 12½ %.

We will of course be blogging on SME Plus Blog and Tax Plus Blog, providing analysis on the key highlights next Monday.

If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.
 

High Court Overturns Special Commissioners Decision in the Grace case

The High Court has overturned a Special Commissioners decision in the case of Commissioners of Revenue & Customs v Grace. According to Taxation magazine this is the first time in 100 years that the court has overturned a Special Commissioner’s ruling.

The case involved an airline pilot who claimed he was non resident in the UK as he had settled in South Africa even though he returned to the UK regularly to carry out the duties of his UK employment.

The case bucked the trend in recent resident cases in that the taxpayer won in front of the Special Commissioners, and he represented himself. Mr Justice Lewison ruled in the High court that that the Special Commissioner (Dr Nuala Brice) had “made errors in arriving at her decision” adding that “the only possible conclusion” was that Mr Grace was resident in the UK.
 

Pre-Budget Report 2008 - Date announced

The Pre Budget report will be on 24 November at 3:30pm according to the Treasury website.

Second Tax Amnesty - It's definitely on its way

HM Revenue have confirmed to the Chartered Institute of Taxation, and other members of the Compliance Reform Forum, that there will be a second Offshore Disclosure Facility, or “opportunity” as it now being referred to as, some time next year. The exact details have yet to be agreed and HMRC are enlisting the help of the CIOT and other professional bodies to make a contribution to the design of the new opportunity”

The HMRC statement on this can be found on the CIOT website. There may be a more public announcement in the Pre Budget Report.
 

Pre-Budget Report 2008 - This Week?

It is being reported by the BBC that Gordon Brown has stated that the Pre Budget Report will be “in a few days”. On GMTV today the Prime Minister increased the speculation that the Chancellor Alistair Darling is considering tax cuts to help people through the down turn.

If Mr Darling does present his Pre-Budget Report this week, we will of course be blogging on SME Plus Blog and Tax Plus Blog, providing analysis on the key highlights.    

If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Watch this space for details as announcements are made.

Budget 2008 - All Settled Offshore?

The Budget announcement today includes some welcome clarifications and relaxations on the extension of the offshore trust capital gains tax rules to non-UK domiciled individuals from 6 April 2008. The main points to note are that :

  • Non-UK domiciled settlors will not be taxed on gains arising to offshore trusts under the “settlor charge”.
  • Non-UK domiciled beneficiaries will not be subject to effective retrospective taxation on gains, or capital payments, arising before 6 April 2008. Offs
  • hore trustees will be able to make an election to rebase assets to 6 April 2008 values so that gains accruing before that date will fall outside the charge to tax for non-UK domiciled beneficiaries.
  • Offshore trust gains arising and matched with capital payments on or after 6 April 2008 will potentially be taxable on non-UK domiciled beneficiaries.
  • Gains arising in respect of UK as well as non-UK assets can be taxed on the remittance basis.
  • The requirement to provide detailed disclosure of information on offshore trusts to HMRC has in large part been dropped.

The changes clearly reflect many of the concerns raised during the consultation process on the draft legislation published in January and are perhaps more generous than expected. This does remove much of the pressure to take significant actions in respect of offshore trusts before 6 April 2008. However, specific advice should be sought in all cases.

Budget 2008 - The Remittance Basis - Offshore Mortgages

It was previously announced that paying interest out of foreign income would be treated as a remittance with effect from 6 April 2008. Today’s Budget has relaxed this proposal in respect of existing mortgages.

Interest payments on existing mortgages, which are secured on a residential property in the UK, that are funded out of untaxed foreign income will not now be treated as a remittance. This will continue for the remaining period of the loan, or until 5 April 2028 whichever is shorter. If the terms of the loan or further advances are made after 12 March 2008 the grandfathering provisions will stop.

Budget 2008 - Non Doms and Capital Losses

Currently Non-doms do not get the benefit of capital losses on foreign assets as the remittance basis is compulsory for capital gains tax. From 6 April 2008 it will be possible to elect in and out of the remittance basis on a year by year basis.

Legislation will be amended so that Non-doms who have not claimed the remittance basis from 2008/09 will get relief for foreign losses. Those non-doms who do claim the remittance basis will be able to elect into a regime that gives them relief for foreign losses in the UK in the years they are taxed on an arising basis. The election will be irrevocable and will require disclosure of unremitted capital gains.

Budget 2008 - Personal allowances and the remittance basis

Proposed changes to the tax rules for Non-Doms had meant that UK residents who took advantage of the remittance basis would lose personal allowances and annual capital gains tax exemptions where their unremitted foreign income and capital gains exceeded £1,000 a year.

Today’s Budget has relaxed this rule slightly and the limit has been increased to £2,000 a year.

Budget 2008 - Non Doms and the £30,000 charge for the remittance basis.

There have a number of changes announced in today’s Budget to the proposed levy of £30,000 for taking advantage of the remittance basis.

The first change to note is that it will only apply to adults. Children will not have to pay the charge until the year in which they turn18. Secondly the de-minimis limit of £1,000 has been raised to £2,000.

The most significant change is that it will now a tax charge rather than a stand alone charge and, as a result, will be treated as such for the purposes of Double Taxation Agreements. This follows serious lobbying by the, particularly American, ex-pat community as it looked like US citizens would not get credit for the £30,000 against their US tax liability.

The charge will be attributed to unremitted income or gains (at the choice of the individual) and when these are eventually remitted to the UK they will not be taxed again. However there will be ordering rules that will ensure that untaxed unremitted foreign income and gains will be treated as remitted before income or gains upon which the £30,000 has been paid.

The £30,000 charge will also be available to cover Gift Aid donations.

Budget 2008 - VAT

The main VAT changes announced in the Budget today are;

  1. With effect from 1 April 2008, the annual VAT Registration/deregistration limits have
    increased to £67,000/£65,000 respectively. 
  2. Revised fuel scale charges will apply for VAT return periods beginning after 1 May 2008.
  3. A transitional period has been announced for VAT refund claims to 31 March 2009. This follows recent litigation relating to the three year capping rules introduced in 1996/7.
  4. Withdrawal of the staff hire concession with effect from 1 April 2009.
  5. A package of simplification measures for the option to tax.
  6. Extension of the VAT exemption for fund management services.
  7. The limits for correcting errors on VAT returns have increased from £2,000 to the greater of £10,000 and 1% of turnover.

    Full details of these changes will be contained in our Budget Tax Bulletin to be issued shortly.

Budget 2008 - Changes to taxation of foreign dividends

Dividends paid by UK companies carry a non-repayable tax credit equivalent to one ninth of the dividend. This means that a basic rate taxpayer has nothing further to pay and a higher rate tax payer pays additional tax at an effective rate of 25%. Dividends from non-UK companies, however, do not currently carry a tax credit and so a basic rate taxpayer will be liable at 10% and a higher rate taxpayer will pay 32.5%.

It was previously announced that from 6 April 2008, provided the dividends did not exceed £5,000 a year, non-UK dividends would carry the same tax credit for shareholders who own less than 10% of the company. Today’s Budget announcement has removed the £5,000 limit. It is not clear what happens where foreign tax has been paid on the dividends.

In addition, the tax credit will be available, from 6 April 2009, for shareholders with more than 10% provided that the source country levies a tax on corporate profits similar to corporation tax. Further details can be found here.

Remittance basis

When the legislation relating to the taxation of overseas dividend was re-written in 2005 an error was made so that remitted dividends (for those claiming the remittance basis) were taxed at 32.5% rather than 40% as they had been in the past. Today’s Budget has announced that this will be corrected with effect from 6 April 2008. The Budget Notice can be found here.

Budget 2008 - Relaxation on Residence Test and Day Counting Rules

Today’s Budget has relaxed the proposed rules for counting the days spent in the UK when determining whether someone is resident in the UK for Tax purposes. It had previously been announced that days of arrival and departure would be counted.

Today’s announcement means that only days where the individual is present in the UK at midnight will be counted as a day of presence in the UK for residence tax purposes. That is days of arrival but not departure.

There is an additional exemption for passengers in transit between two places outside the UK even if they are here at midnight.

Further details can be found here.

Budget 2008

Chancellor Alistair Darling will deliver his first full Budget on Wednesday 12 March 2008. The 2008 Budget comes amid the gloomiest economic situation for more than a decade, with volatile financial markets, a credit crunch and falling house prices.

Mr Darling will present the Budget to the House of Commons at 12.30pm and we will of course be blogging on SME Plus Blog and Tax Plus Blog during the course of the afternoon, providing analysis on the key highlights.

If you do not already subscribe to our blogs click here for SME Plus Blog or here for Tax Plus Blog to ensure you get our comment and analysis as and when it happens.

Inter-spouse transfers and the banking of indexation

My fellow partner and renowned tax lecturer Robert Jamieson has provided me with the following note about “banking” indexation allowance ahead of the new capital gains tax rules which come into force on 6 April 2008.

Shortly after the Chancellor’s announcement that he was abolishing the indexation allowance for individuals with effect from 6 April 2008, tax advisers realised that clients who had accrued substantial indexation up to April 1998 could, in many cases, ‘bank’ the relief by making a simple inter-spouse transfer of the relevant asset before 6 April 2008. Following the no gain no loss transfer under S58 TCGA 1992, the recipient spouse would hold an asset at a revised base cost which was no longer deemed to include an indexation component.

It was then spotted that there was a problem if the asset fell into the rebasing regime on account of the wording in Para 1 Sch 3 TCGA 1992. This states that the recipient spouse will pick up the transferor’s rebased cost and accrued indexation so that the latter would still be lost on a disposal after 5 April 2008. It now appears that HMRC are of the opinion that the draft CGT legislation published on 24 January 2008 deals with this difficulty. If that is the case, it is still not clear which provision addresses the matter.

Reference can be made to the first of HMRC’s FAQs on the CGT reform proposals which reads as follows:

Q. If I make a no gain no loss transfer on or before 5 April 2008, for instance a transfer to my husband/wife, will he/she retain the benefit of any indexation allowance due on the transfer?
A. Indexation allowance will not be stripped out when the person who acquires the asset under a no gain no loss transfer disposes of it after 5 April 2008. For example, in the case of an inter-spousal transfer, indexation allowance will continue to be included, where applicable, in arriving at the allowable cost to the transferee spouse.’

This would seem to bear out HMRC’s professed intention, although astute observers will note that there is no express reference in the FAQ to a 31 March 1982 holding date for the transferor spouse. Interestingly, in the trusts discussion forum, Matthew Hutton has recently mentioned that he saw ‘non-confidential minutes’ of a meeting in November 2007 where HMRC put on record their view that the March 1982 holding period represented ‘an unfairness to the taxpayer which would be corrected by legislation’.

None of the above is very satisfactory for those who want to give definitive advice to their clients (unless they are content to rely on HMRC assurances). However, at the end of the day, what does a taxpayer lose by making an inter-spouse transfer of an asset such as land or shares which predates 31 March 1982?

Robert Jamieson MA FCA CTA (Fellow)

As Robert says there is nothing to lose by making such a transfer but it might be wise to make preparations but wait until the Budget on 12 March to see if the point is clarified.

Government floats CGT concessions

It is being reported by the Daily Telegraph that the Government is considering a number of options relating to concessions on the new capital gains tax regime. One of these seems to be the ability to “opt for a deemed sale” before 5 April 2008 to lock into the favourable business taper and indexation relief. Presumably this would be a way of crystallising a gain without resorting to such devices as trusts.
Continue Reading...

Darling Delays Capital Gains Revisions to New Year

It is being reported that Chancellor Alastair Darling will not be able to announce his revised proposals in the three weeks that had been promised. He told MPs today:



"It is not now going to be possible to conclude that process until the New Year,"

This is because he needed more time to study various, differing representations.

Pre Budget Report 2007 - Inheritance Tax

Any assets passing on death to a spouse or civil partner normally qualify for spouse exemption and no inheritance tax is payable. However, each individual is entitled to a nil rate band allowance (currently £300,000) and, essentially in this scenario, the nil rate band on the first death goes unused. With the use of tax planning Wills, there have been various ways in which the first nil rate band could be rescued. Continue Reading...

Pre Budget Report 2007 - Arctic Systems

An announcement has been widely expected and commented on in this and other blogs (see SME blog) following on from the Revenue’s defeat in the House of Lords. This is a case of the dog that didn’t bark or at least not yet…. Continue Reading...

Pre Budget Report 2007 - Residence and Domicile

The long awaited attacks on the non domiciliary have arrived. Having rubbished the £25,000 levy put forward by the Conservatives, Mr Darling has announced a £30,000 surcharge for those who will have been resident in the UK for 7 years at 5 April 2008. Continue Reading...

Pre Budget Report 2007 - Capital Gains Tax (CGT)

In response to the Pre Budget Report 2007, please find below the thoughts of Cathy Corns, Partner at Mercer & Hole and contributor to SME Plus Blog...

From 6 April 2008 there is to be a dramatic change in the calculation of Capital Gains Tax (CGT). Essentially there will be a flat rate of tax of 18% based on the difference between sale proceeds and cost. This applies irrespective of the type of asset held; the length of time held; removes relief for indexation totally (effectively halving the tax base cost for assets held pre March 1982) and removes a few other mitigation measures.

Continue Reading...

Pre Budget Report 2007 - Initial response

The immediate reaction to the Chancellor’s speech is that much of what he said was smoke and mirrors – The Inheritance Tax doubling of the nil rate band is not quite what it seems – 2 x 300,000 is still 600,000 so far as I know…

The capital gains tax simplification represents a significant increase in tax in a number of cases and if you are non UK domiciled and UK resident then keep checking this page. We are writing frantically as I type and a more detailed and coherent response will follow shortly….

2007 Pre-Budget Report and Comprehensive Spending Review

As mentioned on my colleagues SME plus blog , The Chancellor of the Exchequer, Alistair Darling, will be presenting his 2007 Pre-Budget Report and the outcome of the Comprehensive Spending Review on the afternoon of Tuesday 9th October.

Cathy Corns will post details of important announcements here shortly after the end of his speech.

Subscribe today to receive regular email updates on the latest business news and views from the partners of Mercer & Hole.

Attack on gas guzzlers leaked

The Sunday Times reported yesterday that Alastair Darling was proposing a “purchase tax” on high polluting cars (4x4s etc). Details were obtained from a leaked Treasury document which also revealed that the top rate of road fund tax is also due for a large increase.

The surcharge has apparently been set at £2,000 while at the other end of the scale buyers of very green cars will be able to claim a rebate of £2,000 off the purchase price.

The proposals are strikingly similar to those put forward by the Conservatives as reported in Motor Trader last week.

No doubt all will become clear in next months Pre Budget Report.

Pre-owned assets: Late elections

Where an individual is subject to an income tax charge under the pre-owned assets tax (POAT) rules it is possible to elect for the assets from which the benefits derive to be treated as forming part of their estate for inheritance tax purposes.

The time limit for such elections is currently 31 January following the year of assessment in which the POAT charge first arises. For those individuals who first became liable to the charge in 2005/2006 the deadline came and went on 31 January this year.

Continue Reading...

Budget 2007 - special bulletin edition

Our spring bulletin incorporating our views on some of the hot Budget topics can be located in our publications section here and is available in pdf format for immediate download.

What's in store for the Budget?

It has been announced that Gordon Brown's final Budget as Chancellor of the Exchequer will take place on Wednesday 21 March 2007.

We have already has a significant tightening up on the rules for tax relief in film schemes and similar partnership arrangements as announced on 2 March 2007 - maybe this is setting the scene for a 'tax avoidance' Budget.
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