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22 June 2016

Tax risk: Why tax and risk need to speak the same language

By Giovanni Bracco and Robert Gooding You only have to glance at the newspapers in recent months to realise that tax has become a high profile issue. The tax paid by corporates in particular has become a topic of interest, and not just to HM Revenue & Customes (HMRC). The...

13 June 2016

Money for nothing: why pension funds are paying too much tax

By Hazell Hallam Too few pension funds are giving sufficient priority to operational tax risk management, new research from PwC reveals. As a result, many are missing out on enhanced investment returns In theory, the majority of pension funds do not pay tax; in practice, many funds’ investment returns may...

03 June 2016

Cross border trade online: how Brussels plans to change the rules

Should online retailers be able to stop someone from overseas buying from their site? On 25 May 2016 the European Commission set out proposals to ensure people and businesses can seamlessly transact online with fair competition and protection, wherever they're based. The vision is for a Digital Single Market. But...

31 May 2016

Tax Transparency - To whom and for what purpose?

The UK’s biggest companies remain under pressure to respond to the various stakeholders who are interested in their tax affairs. This increased attention on tax is influenced by a number of factors, including media headlines, changes in regulation and reviews into public disclosure by the Financial Reporting Council. All of...

17 May 2016

Nobody puts operational tax in the corner

PwC’s annual asset management tax conference, held in London in May, discussed the future for asset management in a challenging period of regulatory change and market development – and, in particular, what the role of the asset management tax function will look like in that future. It is four years...

16 March 2016

Allowance for micro entrepreneurs

By John Steveni The new £1,000 allowance for micro entrepreneurs is aimed partly to clear up the confusion around what tax must be declared on peer-to-peer income. The allowance isn't restricted to the so called sharing economy, and will apply to all manner of enterprise, whether using your car to...

New measures on tax administration

By Simon Wilks Although the Budget was wide ranging and contained a lot of measures, there were few entirely new measures in the area of tax administration. However, there is renewed focus on avoidance and evasion with combined measures due to produce £12bn yield by 2020. Much of this relates...

Support for small businesses and entrepreneurs

By Natalie Langley The Chancellor announced his intention to put “rocket boosters on the back of enterprise”. It's fantastic to see support for small businesses and entrepreneurs. They account for a significant amount of employment and innovation in the UK and haven't received much attention in recent Budgets. The potential...

Significant change to stamp duty

By Paul Emery Today’s budget represents the most significant change to stamp duty on commercial property for a decade. While changing from a slab to progressive structure will be welcomed, reducing distortion around the bands, the top rate rising to 5% could cause headaches for the higher end of the...

Personal tax measures overview

By Iain McCluskey and Richard Harryman The Chancellor walked a steady line over a fiscal and political tightrope today as he delivered his 2016 Budget. Bound by a commitment to a surplus by 2020, and tethered to his manifesto promise not to increase headline tax rates, his moves could be...

Winners and losers

By Alex Henderson George Osborne has walked a tight rope in his latest Budget with all of the winners being counter balanced by losers. In choosing his losers he's followed some familiar themes. For large corporates the news is definitely mixed, An extra 1% off the rate of Corporation Tax,...

Supporting the oil and gas industry

By Alan McCrae The Chancellor’s announcement of a reduction in tax rates and effective abolition of Petroleum Revenue Tax is a welcome boost for our oil and gas industry, which has been facing exceptionally challenging times over the last 12 – 18 months. Across the North Sea, this will reduce...

Insurance Premium Tax rate rise

By Ben Flockton Whilst arguably modest if viewed in isolation, this latest rate rise of 0.5% (to 10%) will mean Insurance Premium Tax (IPT) will have increased by two thirds in less than a year. Overall, this equates to an additional IPT cost of over £17 on the average motor...

Small business rates reaction

By Phil Vernon Increasing the small business rates multiplier to capture properties with a rateable value of up to £50,000 is a good headline grabber, but will only save business between £160 at the bottom of the scale and £600 per year at the top. However, the decision to permanently...

Restrictions to tax relief for interest payments

By Stella Amiss The Chancellor has set out his stall for how the UK will implement the OECD's recommendations on imposing restrictions to tax relief for interest payments. All UK businesses with borrowings will have to re-evaluate their tax position on the back of today's announcement. The move will likely...

15 March 2016

Budget 2016: What it really means for you?

By Stella Amiss This Budget is an opportunity for the Chancellor to try and lay the groundwork for the uncertain times ahead. Both the domestic and international backdrop cannot be ignored. Whilst this is an opportunity for the Chancellor to enact major reforms and address some of the long trailed...

11 March 2016

Pension tax reform: the race is still on

By Tim Sexton The Chancellor’s surprise briefing through trusted allies that “there won’t be any changes in pension tax relief at all in the Budget” is far from the end of the story. For this Budget at least, the field has changed and the political factors that have delayed pensions...

09 March 2016

The UK CBCR legislation is final, the question is who is impacted and what should you do?

By Peter Barlow On 26 February 2016 the UK published its final country-by-country (CBC) regulations. I have previously discussed What does CBCR mean for you? Five key questions companies need to address now? so the question we are asking today is "do the UK regulations change those plans?" For the...

22 February 2016

PwC Legal event - Transparency in an ever changing regulatory environment - are you ready to disclose?

By Matt Timmons With increased demand for greater transparency in the way global corporations are managed, national governments have been focused on their legislative agendas to introduce key reforms to achieve this. Join us to understand the latest UK legislative developments and the impact these are having on corporate reporting....

15 February 2016

The jury's out on intergenerational fairness

By Laetitia Lynn "Life is so much easier for your generation". The words of a parent or their child? You can argue it both ways. Some baby boomers may now be enjoying healthy, prosperous retirements with holidays a plenty, but this may follow years of frugality, devoid of travel, or...

12 February 2016

Are you ready to publicly disclose?

disclose ownership, PSC register, disclosure rules, internal governance, PwC, control protocols, companies house

28 January 2016

Capital Markets Union – Unlocking the potential for European growth

Join our live webcast 23 February – 15:00 Register here. The Capital Markets Union (CMU) is a European initiative that will change the landscape of the European capital markets. Amongst other things, the reforms that the CMU will introduce will change: public equity markets the securitisation markets; and the landscape...

26 January 2016

A head start on the transition to VAT in Egypt

Draft legislation on the introduction of a VAT system in Egypt is expected to be implemented in 2016 Although the timing is unclear, as a decision will be made by the newly elected parliament, there is an expectation that the current Sales Tax will transition to a Value Added Tax...

21 January 2016

HMRC withdraws Accelerated Payment Notices (APNs) and Partner Payment Notices (PPNs)

Overview HMRC has recently withdrawn a substantial number of Accelerated Payment Notices (APNs) and Partner Payment Notices (PPNs), which it had previously issued to taxpayers. The effect of an APN or PPN is to require payment of tax which is in dispute up front, with no right of appeal. Individuals...

18 December 2015

How will the new patent box regime impact innovation?

By Angela Browning HMRC released draft legislation on 9 December 2015, setting out how patent box will be modified going forward. The positive news is that this broadly follows the structure and content trailed, so there are relatively few surprises for those of you already familiar with Nexus. It is...

04 December 2015

Global Mobility and BEPS - How prepared is your organisation?

By Gemma Buxton The final Base Erosion and Profit Shifting (BEPS) package was published on 5 October 2015. Throughout, the direct implications for global mobility teams has been less publicised but BEPS is just as relevant nonetheless. There will be a number of actions that will affect how organisations deploy,...

Patent box – IP transfer deadline 31 December 2015

By Angela Browning Heading into the holiday season the last thing on your mind may be the patent box, but that definitely shouldn’t be the case. As discussed previously here and here we’re heading into a crucial time for patent box, and intellectual property as a whole. The patent box...

03 December 2015

Building Public Trust through Tax Reporting

By Mary Monfries There can be little doubt that concern about companies paying their "fair" share of tax has impacted public trust in business. It's equally true that people often underestimate the amount of tax companies pay. How do you reconcile these two positions? I can already imagine people questioning...

25 November 2015

Autumn Statement 2015 – what we could expect

By Stella Amiss Tomorrow, Wednesday 25 November we’ll see the Chancellor deliver the Conservative Government’s first Autumn Statement and third budgetary speech from Mr Osborne this year! This Autumn Statement comes with a twist as it will be combined with the Spending Review announcement. This is an opportunity for the...

17 November 2015

What we all learnt - our pilot initiative teaching teenagers about tax

By Laetitia Lynn Wow what a day we had with a fantastic bunch of London sixth-formers. No matter how much time we'd spent planning the session, part of me wondered how well the class would go down with these young minds. Lets face, tax sounds dry. But as we've seen...

BEPS and IP – it’s all about substance

By Adrian Gregory Intellectual property (IP) is a classic example of a highly mobile asset, and so it’s no surprise that it’s come under the microscope during the OECD’s BEPS project. While there’s not one BEPS action that deals with IP in the round, most of the BEPS announcements made...

13 November 2015

Taxing the sharing economy

By John Steveni Since we lived in caves, humans have shared our time and property with others. We do things for our friends and neighbours, sometimes for money, sometimes in exchange for a good deed in return, and sometimes without expectation of anything at all; it’s one of the things...

05 November 2015

Teaching Teenagers about Tax

By Stella Amiss If you'd told me when I was at school that I'd end up working in tax I'd have looked more than a bit puzzled. It's not just that I'd harboured hopes of being a mechanic or a news reader but more that I had absolutely no idea...

BEPS – Adapting to a changing digital economy

By John Steveni The BEPS Digital Economy Report provides a good summary of how the international tax system developed and why the digital economy causes tensions. It deals with the concern that the international tax rules cannot cope with the new types of businesses which are being created in response...

02 November 2015

Patent box: Why tax professionals need to be part of R&D decisions

By Angela Browning Patent box can be an extremely valuable incentive for companies that are able to claim. As we explained in our previous blog, this means that it’s essential that eligible companies get organised as critical deadlines are fast approaching. But the incentives offered by patent box raise another...

29 October 2015

Requirement to disclose related undertakings

By Matt Timmons Background Section 409 of the Companies Act 2006 (the "Act") requires all companies to disclose information in respect of their related undertakings[1] in the notes to their financial statements. Section 410 of the Act previously offered a concession to this requirement, by allowing for the omission of...

27 October 2015

How a ‘shapie’ exposes the permanent establishment (PE) problem

By John Steveni In my last post I wrote about how any system that’s based on rules brings uncertainty – and that’s certainly true of the international tax system. Digital business adds a new dimension to the way companies operate – and international tax law, designed for the industrial age,...

22 October 2015

BEPS: Tax treaties – do you have everything in place?

By Trudy Armstrong We’ve now seen the culmination of an ambitious two year project to reform the international tax rules for business. The Organisation for Economic Co-operation and Development (OECD) has been poring over every aspect of tax that it feels isn't working for today's world, and we've now seen...

20 October 2015

International tax law for digital business: Time for a parking ticket?

By John Steveni I’ve written in the past about the challenges of applying industrial-age tax rules to digital age businesses. It’s one of the biggest problems the tax authorities face, but recently the debate in the press has focused on whether digital businesses pay the right amount of tax, rarely...

16 October 2015

Time for the uber tax collector?

By John Steveni One of the knock-on effects of digital technology is that it’s pushing us away from traditional employment and towards a network of self-employed relationships – what is often referred to as the ‘gig economy’. Digital technology is especially adept at matching people to opportunities; from Uber drivers...

22 June 2016

Commission welcomes agreement reached by Member States on new rules to tackle tax avoidance

Agreement by EU Member States on their general approach for far-reaching new rules to eliminate the most common corporate tax avoidance practices have been agreed in a draft Anti-Tax Avoidance Directive. First proposed by the Commission in January, as part of an Anti-Tax Avoidance Package, these legally-binding rules build on...

16 June 2016

Unemployment down as more people in work than ever before

Official figures from the Office for National Statistics released recently show the unemployment rate now stands at 5.0% and there are nearly 31.6 million people in work. Department for Work and Pensions press release

15 June 2016

Finance Bill 2016: Proposed government amendments

On 13 June, the government recently tabled a large number of amendments to be considered by the Committee of the whole House on Monday 27 and Tuesday 28 June. www.publications.parliament.uk/pa/bills/cbill/2016-2017/0001/amend/finance_rm_cw h_0613a.pdf

OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations

On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("Transfer Pricing Guidelines"), as set out in the 2015 BEPS Report on Actions 8-10 "Aligning Transfer Pricing Outcomes with Value Creation" and the 2015 BEPS Report on Action 13...

14 June 2016

Finance Bill 2016: Committee stage

A Committee of the whole House will debate selected parts of the Finance Bill on 27 and 28 June. The Bill has been carried over to the new parliamentary session and was given a formal first and second reading without debate on 19 May. See: http://services.parliament.uk/bills/2016-17/finance.html

HMRC updates SP 10/1991: major change in the nature or conduct of a trade or business

HMRC has republished this statement of practice, restoring content which had dropped off its website in transition to GOV.UK. This statement explains the basis on which HMRC interpret the term ‘a major change in the nature or conduct of a trade’ for various corporation tax purposes. Document Statement of Practice...

Treasury seeks permanent Tax Director for Office of Tax Simplification

The Treasury has opened the recruitment process for a permanent Tax Director to lead the Office of Tax Simplification (OTS), following the announcement that John Whiting will be stepping down as Tax Director. The deadline for applications is midnight on Thursday 14 July 2016. See: https://www.gov.uk/government/news/treasury-seeks-permanent-tax-director-for-office-of-tax-simplification

13 June 2016

EU Parliament supports tougher anti-tax avoidance directive

The EU Parliament has passed a resolution to take forward the anti-tax avoidance directive, approving recommendations made by the Economic and Monetary Affairs Committee in May which go beyond the Commission's original proposals on a number of measures. European finance ministers are due to discuss the directive at the next...

09 June 2016

Wales Bill introduced to Parliament

The Secretary of State for Wales, Alun Cairns MP has introduced the Wales Bill in Parliament. The Bill will make Welsh devolution clearer and stronger by introducing a reserved powers model to clarify the division of powers between the National Assembly for Wales and Westminster, and devolving important powers to...

07 June 2016

EU Commission publishes Working Paper on State aid and tax rulings

The European Commission recently published a working paper on State aid and tax rulings. It follows on from the finalisation of its Notice on the Notion of State Aid. European Commission Working Paper on State Aid and Tax Rulings (3 June 2016) See: http://ec.europa.eu/competition/state_aid/legislation/working_paper_tax_rulings.pdf

06 June 2016

Company cars - advisory fuel rates from 1 June 2016

HMRC has published revised advisory fuel rates for company cars, applying from 1 June 2016. The rates are to be used only where employers either reimburse employees for business travel in their company cars, or require employees to repay the cost of fuel used for private travel. www.gov.uk/government/publications/advisory-fuel-rates

01 June 2016

Consultation on local government pension scheme regulations

The Department for Communities and Local Government (DCLG) is seeking views on proposals to ensure that local government and participating employers in the local government pension scheme, provide the appropriate level of pension provision as set out in the new Fair Deal guidance. The consultation closes on 20 August 2016....

Draft legislation: the Bank Levy (Amendment of Schedule 19 to the Finance Act 2011) Regulations 2016

HM Revenue and Customs has published draft regulations, together with a draft explanatory memorandum, for a period of consultation which will close on 30 June 2016. Draft regulations Draft legislation: the Bank Levy (Amendment of Schedule 19 to the Finance Act 2011) Regulations 2016 A tax information and impact note...

HMRC consults on Double Taxation Treaty Passport (DTTP) scheme

This consultation will enable HMRC to review the scheme to ensure that it still meets the needs of UK borrowers and foreign investors. It also seeks views on extending the scope of the DTTP scheme to investors entitled to sovereign immunity from UK tax (“sovereign investors”), pension funds and other...

Off-payroll working in the public sector: reform of the intermediaries legislation

This consultation is about reforming the intermediaries legislation to improve its effectiveness in the public sector. It seeks views on the impacts of this change and design details of the policy, including a new process to help determine whether an intermediary is in scope of the rules. The deadline for...

27 May 2016

HMRC taskforces raise more than half a billion

HMRC taskforces have recovered more than £500 million since they were launched in 2011. More than 140 taskforces have targeted sectors that are at the highest risk of tax fraud including the retail sector, the tobacco industry and the adult entertainment industry. Press release Click here to view full Press...

HMRC issues Help to Save: consultation on implementation

HMRC have issued a consultation on the Help to Save scheme which is to encourage people on low incomes to build up a rainy day fund. The consultation seeks views on the framework for implementing the scheme and detailed policy design issues. The deadline for responses is 21 July 2016....

Landfill Tax: improving clarity and certainty for taxpayers - consultation

HMRC have issued a consultation on proposals to amend the definition of a taxable disposal at a landfill site and for information on the disposal on certain types of hazardous material. The deadline for responses is 18 August 2016. Documents Landfill Tax: improving clarity and certainty for taxpayers

26 May 2016

HMRC consults on reform of substantial shareholdings (SSE) exemption

This consultation considers possible reform of the SSE, with a view to modernising and broadening it, and increasing its simplicity, coherence and international competitiveness. A number of options are discussed including a 'comprehensive share disposal exemption' but with appropriate conditions and protections. Other options include retaining the existing exemption and...

DWP consults on capping early exit charges for members of occupational pension schemes

This consultation seeks views on government plans to cap early exit charges in occupational pension schemes that contain flexible benefits. The deadline for responses is 16 August 2016. Capping early exit charges for members of occupational pension schemes

HMT and HMRC consult on reforms to corporation tax loss relief: consultation on delivery

This consultation considers how best to deliver proposed reforms in corporation tax loss relief legislation, and how to deal with the interactions with other areas of the corporate tax system. Of particular note are: losses arising post April 2017 can be utilised more flexibly against all classes of income, both...

25 May 2016

Over 55s at heightened risk of fraud, says Financial Conduct Authority (FCA)

The FCA is urging caution as a study reveals an increasing risk of retirees being scammed via investment fraud. Low interest rates are cited as a key driver as investors seek higher returns. Over 65s with savings in excess of £10,000 are three and a half times as likely to...

Lord Sugar appointed government’s enterprise tsar

Lord Sugar has been appointed enterprise tsar as part of government’s drive to get more young people to start their own business or an apprenticeship. Press release: https://www.gov.uk/government/news/lord-sugar-appointed-governments-enterprise-tsar

Effects of taxes and benefits on UK household income: financial year ended Mar 2015

The Office of National Statistics have released information on how income is redistributed through taxes and benefits and how income inequality has changed over time for different types of households. Effects of taxes and benefits on UK household income: financial year ending Mar 2015

Consultation on power to disqualify from acting as a trustee

Consultation on the Charity Commission’s proposed approach to using the new statutory power to disqualify individuals from acting as trustees. Deadline for response is 22 August 2016. See: https://www.gov.uk/government/consultations/consultation-on-power-to-disqualify-from-acting-as-a-trustee

Anti-tax avoidance: MEPs call for minimum corporate tax rate of 15%

The European Commission's proposal for an EU anti-tax avoidance directive was welcomed by Parliament's Economic and Monetary Affairs Committee in a resolution voted on Tuesday. MEPs nonetheless advocated stricter limits on deductions for interest payments and an effective corporate tax rate of 15%. Press release: http://www.europarl.europa.eu/news/en/news-room/20160523IPR28574/Anti-tax-avoidance-close-tax-gap-with-low-tax-third-countries-say-MEPs

Double Taxation Relief and International Tax Enforcement (United Arab Emirates) Order 2016

This draft order will bring into effect the UK/United Arab Emirates Double Taxation Convention, signed on 12 April 2016. The convention has not yet entered into force. www.legislation.gov.uk/ukdsi/2016/9780111147016

The Quality of Service to Personal Taxpayers inquiry

The Public Accounts Committee (PAC) is to hold a session on the quality of service to personal taxpayers on Monday 13 June 2016 at 4.00pm. The deadline for written submissions is midday on Tuesday 7 June 2016. Scope of the inquiry

23 May 2016

Closing the VAT gap in the CEE countries

By Christine O’Malley We are organising the second in a series of conferences on "Closing the VAT gap in the CEE countries" on the 23 June 2016. We will bring together public finance officials, leading tax consultants and business representatives of 5 CEE countries (Czech Republic, Hungary, Poland, Romania, Slovakia)...

20 May 2016

Minister for Intellectual Property (IP) introduces the IP (Unjustified Threats) Bill

The new Unjustified Threats Bill provides greater clarity for right holders and third parties that become involved in IP disputes. Changes introduced by the Bill will help create an IP environment that favours negotiation and settlement rather than litigation. Link to article Click here to view Press release.

18 May 2016

Queen's Speech 2016 sets legislative programme

The Government's legislative programme for the 2016/17 session of Parliament was announced in the Queen's Speech today (18 May 2016). Link to Queens speech Queen's Speech 2016: background briefing notes

HMRC draft guidance on the 2015 changes to the EIS regime

Following the legislation enacted in Finance (No.2) Act 2015 making far-reaching changes to the EIS regime, HMRC has issued draft guidance on those changes to its Venture Capital Schemes Manual. Guidance HMRC has now published guidance on these new rules.

BEPS and global mobility: Why should I care about it now?

By Sarah Mullen We’ve previously made the case for how the Base Erosion and Profit Shifting (BEPS) changes will require those responsible for globally mobile employees to take action at some point to manage the changing landscape of the corporate risks of mobility (see our short video http://bit.ly/20A33x7 ), but...

17 May 2016

HMRC guidance on the Capital Gains Tax treatment of Employee Shareholder shares

Revised version of HMRC guidance on the Capital Gains Tax treatment of employee shareholder shares. The main change is to add the new rules from Budget 2016. Guidance This guide gives information on Capital Gains Tax treatment (CGT) of Employee Shareholder (ES) shares. Guidance on the Capital Gains Tax treatment...

16 May 2016

Heads of tax administrations take big step forward in global tax co-operation

Delivering on the OECD/G20 international tax agenda, through implementation of the Base Erosion and Profit Shifting (BEPS) Project and the Common Reporting Standard (CRS) for the automatic exchange of financial account information, took centre stage when Heads of Tax Administration met on 11-13 May in Beijing, China. Press Release http://www.oecd.org/tax/heads-of-tax-administrations-take-big-step-forward-in-global-tax-co-operation.htm

HM Treasury has published a list of countries which have committed to sharing beneficial ownership information

HMT has published a list of countries which have committed to the initiative to automatically exchange information on beneficial ownership. The next stage will be for the development of a global standard for this exchange. The list includes the Cayman Islands, which has been the subject of much attention in...

13 May 2016

A new boost to transparency in international tax matters: six new countries sign agreement enabling automatic sharing of country-by-country reporting

As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Canada, Iceland, India, Israel, New Zealand and China have recently signed the Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports (CbC MCAA), bringing the total number of signatories to 39 countries. The signing ceremony took...

Tax deductibility of corporate interest expense: consultation on detailed policy design and implementation

In this consultation the Government is seeking views on the detailed policy design and implementation of new rules on the tax deductibility of corporate interest expense. Consultation Following initial consultation on the OECD’s recommendations, the Government announced key policy design features for a restriction on the tax deductibility of corporate...

Office of Tax Simplication: Simplifying tax for the future – a consultation on our future strategy

The Office of Tax Simplification (OTS) was established in 2010 to be an independent office of HM Treasury to make recommendations on how to simplify tax in the UK. The 2016 Finance Bill will place the OTS on a permanent statutory basis and this strategy consultation document sets out, and...

ECJ launches its first app for smartphones and tablets

The Court of Justice of the European Union has launched its application, CVRIA, for smartphones and tablets. It has four sections: case law, press releases; judicial calendar; and a search function. The search function allows searches to be made by case number, parties’ names and date and in full text...