The size of the UK's 'legal interpretation tax gap' is a matter of increasing concern to the government, so much so that it has now published its second consultation on the topic. A 'legal interpretation tax gap' arises where...more
The Finance Bill 2021 sets out a more sustainable and environmentally friendly tax system by legislating to implement a plastic packaging tax (the "Tax"). The new Tax will encourage the use of recycled plastic within...more
On the eve of the UK's exit from the EU on 31 December 2020, the UK Government published the concise but game-changing piece of legislation, 'The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2)...more
The Government is pressing ahead with its proposed UK 'freeports' initiative, described as a 'flagship government programme' by HM Treasury, which aims to increase the attractiveness of the UK as an international trading...more
On December 8 and 10, Katten’s Structured Finance and Securitization Department presented the “Year in Review and Outlook for 2021” webinar series. Topics covered by Katten attorneys and guest speakers include the impact of...more
12/24/2020
/ Biden Administration ,
Coronavirus/COVID-19 ,
EU ,
FDIC ,
FinTech ,
Libor ,
Loans ,
OCC ,
Regulatory Oversight ,
Safe Harbors ,
Tax Reform ,
UK ,
UK Brexit
HM Revenue and Customs (HMRC) has adopted a new position regarding VAT on contractual termination payments and cancellation fees....more
Following on from the announcement in the 2018 Budget, from 1 April 2021 non-UK resident purchasers of residential property in England and Northern Ireland will be subject to a new higher rate of SDLT of 2 percentage points...more
The Finance Act 2020 includes provisions (the body of which are in Schedule 16 to the Act) clarifying the tax treatment of payments made by the UK Government to alleviate the effects of COVID-19 on the economy and the...more
Finance Act 2020: This Time It’s Personal (Liability) -
The Finance Act 2020 introduces new rules which make certain individuals who have a ‘relevant connection’ to a company that is, or is likely to become, subject to an...more
Key Points -
- COVID-19 has caused a rise in variations of commercial leases;
- HMRC has published a briefing paper to help landlords and tenants comply with appropriate tax legislation by providing guidance on VAT and...more
From 6 April 2020, non-UK tax resident corporate landlords (NRLs) are subject to corporation tax rather than income tax on their UK rental profits. Prior to this change, NRLs were subject to income tax (through withholding...more
Principal private residence relief (PPR) provides an individual disposing of their main or principal place of residence (their ‘dwelling-house’ — such term is not defined in the legislation, but generally includes buildings...more
IR35 off payroll rules1 and employee's NICs by supplying their services through an intermediary, such as a personal services company (PSC), and paying themselves in dividends from that company....more
Key Points -
- The DRC will affect around 150,000 businesses in the construction industry
- It will require those receiving a supply of construction services to account for VAT directly to HMRC
- In particular, it...more
In the 2018 Autumn Budget, the Chancellor announced his intention to reintroduce Crown Preference with effect from 6 April 2020. Due to the attempts to prorogue Parliament and the General Election last year, the necessary...more
The Spring 2020 Budget included confirmation that a new UK digital services tax (DST) comes into effect from 1 April 2020. DST was originally announced in the 2018 Budget as a new tax designed to ensure that the amount of tax...more
Entrepreneurs' relief (ER) provides for a lower rate of capital gains tax (10 percent) to be paid when disposing of all, or part, of a business, or shares or securities in a personal company, or shares from an EMI scheme,...more
KEY POINTS
- The UK Regulations, finalised on 13 January 2020, will only apply in relation to direct EU taxes.
- The Legal Professional Privilege exemption is still unclear.
- Penalties have been capped at...more
2/8/2020
/ Anti-Avoidance ,
Cross-Border Transactions ,
Disclosure Requirements ,
EU ,
HMRC ,
Intermediaries ,
International Tax Issues ,
Legal Professional Privilege ,
New Legislation ,
Reporting Requirements ,
Tax Authority ,
Transitional Arrangements
Key Points
- Coming into force on 1 July 2020, EU DAC6 Regulations will require intermediaries in certain cross-border arrangements to disclose activity to tax authorities.
- The DAC will apply retroactively to affected...more
12/12/2019
/ Anti-Avoidance ,
Corporate Counsel ,
Cross-Border Transactions ,
Disclosure Requirements ,
EU ,
HMRC ,
Intermediaries ,
International Tax Issues ,
Legal Professional Privilege ,
Member State ,
New Regulations ,
Tax Authority ,
Tax Avoidance ,
Third Country Entities (TCEs)
Key Points
- The off-payroll rules (IR35) aim to stop individuals from avoiding employee status for tax purposes (and thereby reducing the income tax and National Insurance Contributions (NICs) payable) by supplying their...more
12/9/2019
/ Employer Liability Issues ,
HMRC ,
Income Taxes ,
Intermediaries ,
Investment Management ,
New Rules ,
Off-Payroll ,
Payroll Taxes ,
Personal Services ,
Public Sector ,
UK
The UK Government has recently proposed further changes to the Entrepreneurs' Relief rules which could make it easier to obtain Entrepreneurs' Relief in certain cases....more
In the UK Government's Fall 2018 budget (Budget), recent changes were announced to Entrepreneurs' Relief to ensure that relief is available only to "genuine entrepreneurs". Entrepreneurs' Relief reduces the rate of capital...more