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09 August 2016

What are the UK CEOs’ thoughts on tax for the year ahead?

By Andrew Packman In a recent blog on our 19th CEO survey, PwC’s Global Head of Tax, Rick Stamm, looked at the role that tax can play in meeting the ever-increasing expectations that stakeholders have for business around a broad range of issues. PwC’s CEO survey shows that for many...

21 July 2016

HMRC and legacy remuneration tax arrangements – the changing landscape

By Jessica McLellan Recent years have meant a sea change in terms of HMRC’s approach to remuneration tax arrangements such as Employee Benefit Trusts and contractor loan schemes, resulting in new legislation, settlement opportunities as well as HMRC’s preparation of key test cases for Tribunal. The last 6 years have...

15 July 2016

Brexit: Is Cutting Corporation Tax the Right Way to Go?

By Kevin Nicholson Now we have a new Chancellor, it's unclear whether recently announced plans to cut corporation tax further will continue. Does this matter? Certainly the headline rate of tax sends a powerful message internationally. Businesses tell us that tax is an important consideration as they weigh up where...

Why governments are excited about blockchain?

By Justin Blackburn John Steveni and Paul Smith blogged recently about the impact that blockchain will have on the way we do business, and in particular on the global tax system. It’s likely that blockchain will impact on many areas of our lives but one area that’s being watched with...

05 July 2016

Indirect tax implications of a Brexit vote on VAT

By Martin Blanche and Johnathan C Davies As we briefly mentioned in our last post on the indirect tax implications of Brexit, the wider outcomes of the referendum vote to leave the EU are yet to be revealed it is likely that VAT will be impacted. As a tax driven...

01 July 2016

Blockchain – will it revolutionise tax?

Posted by John Steveni and Paul Smith A few weeks ago, construction workers in London unearthed hundreds of Roman writing tablets, including some of the earliest known examples of receipts and IOUs. The find reminded us that, essentially, the way in which we record transactions has barely changed in 2,000...

29 June 2016

What could Brexit mean for UK innovation incentives?

By Angela Browning Many companies have asked me over the past week what Brexit could mean for UK innovation incentives like R&D credits, patent box, EU and national grant funding. Whilst the easy, obvious answer is that it is too early to say, I could go further and say that,...

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...

24 August 2016

Statutory Residence Test (SRT) - HMRC personal tax guidance

This guidance note gives information on the new Statutory Residence Test (SRT) introduced for tax years 2013 to 2014 onwards and how HMRC interprets the legislation in the context of applying the SRT to an individual’s circumstances. Some amendments have been made for 2016. Document Guidance note for Statutory Residence...

19 August 2016

Reforming business rates appeals: draft regulations for consultation

The Department for Communities and Local Government are seeking views on draft regulations to support the business rates appeals reforms. The deadline for comments is 11 October 2016.  Documents  Check, challenge, appeal: reforming business rates appeals - consultation on statutory implementation

Upper Tribunal decides Icebreaker case in favour of HMRC

The Upper Tribunal (UT) has confirmed the First Tier Tribunal (FTT) decision that the Icebreaker scheme failed. Investors in the scheme were members of 51 partnerships set up by a company called Icebreaker Management. The members of the scheme claimed to be active partners trading in the creative industries and...

Soft drinks industry levy consultation

A consultation on a new UK-wide Soft Drinks Industry Levy that will apply to the production and importation of soft drinks containing added sugar. The consultation closes on 13 October 2016.   Soft Drinks Industry Levy - consultation

18 August 2016

Tax disputes - is now the time to settle?

By Jonathan Preshaw Many disputes involving historic tax planning remain unresolved. Estimates of the number of open disputes vary, but there is no doubt that there are many thousands, and that the tax involved runs to many hundreds of millions of pounds. With that in mind, HMT and HMRC continue...

16 August 2016

Chancellor Philip Hammond nominates Sir Charles Bean for appointment to the Office for Budget Responsibility

The Chancellor has nominated Sir Charles Bean for appointment to the Budget Responsibility Committee (BRC) of the Office for Budget Responsibility (OBR). Led by the Chairman, Robert Chote, the BRC has executive responsibility for the core functions of the OBR and is responsible for judgements reached in OBR economic and...

15 August 2016

Simplification of the tax and National Insurance treatment of termination payments - draft legislation

The government has published a follow-up consultation on draft legislation in response to the summer 2015 consultation on termination payments. This explains the policy underpinning the changes in greater depth. Comments are needed by 5 October 2016. Consultation on draft legislation Simplification of the tax and National Insurance treatment of...

Company car tax for ultra-low emission cars - HMT consultation

This consultation is seeking views on options to refocus incentives on the cleanest cars using the latest technologies. The consultation closes on 20 October 2016. Documents Company car tax for ultra-low emission cars

Salary sacrifice for the provision of benefits-in-kind - HMRC consultation

Consultation on limiting the range of employee benefits-in-kind that attract Income Tax and National Insurance Contributions advantages when provided as part of salary sacrifice arrangements. Comments should be submitted by 19 October 2016. Document Consultation on salary sacrifice for the provision of benefits-in-kind

HMRC to consult on Stamp duty land tax: changes to the filing and payment process

A consultation on proposals to make the stamp duty land tax (SDLT) filing and payment process faster and easier. The consultation closes on 7 October 2016. Document Stamp duty land tax: changes to the filing and payment process

Tackling Disguised Remuneration: technical consultation

This technical consultation includes more detail on the changes the government will introduce in Finance Bill 2017. In order to provide as much detail as possible an early draft of the legislation has been included in the consultation document. This consultation also includes details of proposals to tackle similar schemes...

HMRC consultation on Partnership taxation: proposals to clarify tax treatment

A consultation to develop detailed design changes to partnership taxation in the context of the wide variety of modern partnerships. The consultation covers areas where the government has identified that the tax rules may be seen as unclear or produce an inappropriate outcome. The deadline for comments is 1 November...

HMRC consults on lease accounting changes for plant and machinery

Changes to lease accounting by the International Accounting Standards Board (IASB) will necessitate changes to the existing tax rules for the leasing of plant or machinery. HMRC are seeking views from all interested stakeholders on possible options for the tax changes required. The deadline for comments is 30 October 2016. ...

HMRC consults on tax treatment of freeplays in remote gaming duty

A consultation on draft legislation to align taxation of free gaming in Remote Gaming Duty with that of free bets in General Betting Duty. The deadline for comments is 17 October 2016.  Documents   Tax treatment of freeplays in Remote Gaming Duty

11 August 2016

HMRC considers applying the GAAR to certain employee reward plans

By Stephen Morse We have seen the first indication that HMRC are considering invoking the General Anti-Abuse Rule ('GAAR').  You may be aware that the GAAR came into effect in July 2013 and enables HMRC to counteract a perceived tax advantage where they consider arrangements to be 'abusive'. Until now,...

Simplifying the PAYE Settlement Agreement (PSA) process - HMRC consultation

This consultation sets out proposals to reform the PAYE Settlement Agreement (PSA) process, to: 1) make it simpler for both employers and HMRC to administer PSAs; and 2) provide greater clarity about what can and cannot be included in a PSA. The deadline for comments is 18 October 2016.  ...

HMRC to consult on alignment of dates for ‘making good’ on benefits-in-kind

The consultation explores the scope for aligning the ‘making good’ rules for benefits-in-kind with those which apply to ‘making good’ where the employer accounts for the benefit-in-kind in real time through Pay As You Earn. The aim is to have a simpler and clearer system that makes it easier for...

09 August 2016

Shale Wealth Fund - consultation

The government is consulting in order to seek views on the delivery method and priorities of the Shale Wealth Fund. The Shale Wealth Fund proposals have been changed to include the option to give more of the proceeds to local residents. 1) The Prime Minister has said that options to...

Changes to how Valuation Office Agency value some non-domestic properties with more than one occupier - what does it mean for ratepayers

A Supreme Court decision about how the Valuation Office Agency (VOA) values non-domestic buildings which are occupied by more than one person or a business could mean a change in business rates for some ratepayers. The decision means that the VOA have revised how they value properties where occupiers use...

05 August 2016

HM Treasury consults on mutual deferred shares technical policy details

HM Treasury is seeking views on the government's proposed Mutuals' Deferred Shares Regulations, which will allow mutual insurers to issue this new type of capital created by the Mutuals' Deferred Shares Act 2015. The deadline for response is 30 September 2016.   Mutual deferred shares: consultation on technical policy details

The Indian Parliament passes GST Constitution Amendment Bill

By Christine O’Malley The Indian Parliament has voted unanimously to introduce the Goods and Services Tax (GST). This is a significant development which will affect all businesses with interests in India or who trade with India.  We understand that the Government is likely to push for 1 April, 2017 as...

04 August 2016

Just business as usual for EU grant funding

By Angela Browning You would be forgiven for thinking that UK business and academia are less inclined to apply for EU funding following the EU Referendum outcome on 23 June 2016. But what we have seen is quite the opposite. PwC hosted two working group meetings in June and July...

03 August 2016

Brexit implications for Scotland - request for views

The Scottish Parliament Committee investigating the implications for Scotland leaving the EU has extended its inquiry and has issued a call for views in order to get more evidence on the impact of the vote. The deadline for submission is 5 September 2016.   See: http://www.parliament.scot/newsandmediacentre/100432.aspx

EU Commission consults on a potential EU personal pension framework

The Commission aims at encouraging more savings into personal pensions to secure adequate revenues for retirement. This is seen to be essential as people are living longer, public finances are expected to remain under pressure and the ratio of retired people to workers is set to double in the next...

02 August 2016

Updated guidance as new social investment power for charities comes into force

The Charity Commission has recently published updated guidance to reflect the new statutory power for charities to make social investments. The new legislation does not alter or override trustees’ general common law duties, and the guidance makes clear that these duties apply to any decision regarding social investments. However, the...

Scottish Government consults on devolved social security benefits

The Scottish Government is consulting until 28 October 2016 on how to implement its devolved powers over certain social security benefits which will account for around £2.7 billion, or 15%, of the total Scottish benefit bill.  See: https://consult.scotland.gov.uk/social-security/social-security-in-scotland 

01 August 2016

Business Rates – Changes for 2017 and beyond

From April 2017 1.94m non-residential properties will be revalued for business rates for the first time in seven years. New Rateable Values to be allocated to all commercial properties in England and Wales. Business rates are property-based tax, collected by Local Councils to fund local services. They are broadly based...

29 July 2016

Tax-Free Childcare: Top things parents and childcare providers should know

Tax-Free Childcare is a new government scheme to help working parents with the cost of childcare. Parents will be able to open an online account, which they can use to pay for childcare from a registered provider. For every £8 a parent pays in, the government will pay in extra...

Pension schemes: protect your lifetime allowance: how to apply for protection

The standard lifetime allowance was reduced to £1.25 million on 6 April 2014 and £1 million on 6 April 2016, but you may be able to protect your pension(s) from these reductions.  See: https://www.gov.uk/guidance/pension-schemes-protect-your-lifetime-allowance

28 July 2016

Union cabinet approves amendments to GST constitution amendment bill

As per news reports, the union cabinet has approved the following amendments to the GST constitution amendment bill:   Proposal to levy 1 percent additional tax on inter-state supply of goods is dropped.   Central Government has agreed to compensate the States for the first 5 years, which was earlier...

HMRC fraud investigations into users of Employee Benefit Trusts

Overview: HMRC are issuing Code of Practice 9 letters.  These investigations cover all tax affairs over the last 20 years, not just the EBT.   Anyone with outstanding Employee Benefit Trust (EBT) arrangements should look at them again to assess the risks and options.  We understand that HMRC is issuing letters...

26 July 2016

Single Market: Commission launches consultation on the Single Digital Gateway

The public consultation on the creation of a 'Single Digital Gateway' has opened. The Gateway would provide easy online access to Single Market information, procedures, assistance and advice for citizens and businesses. The deadline for responses is 21 November 2016.   Click on this link to see the consultation details

EU Commission: Public Consultation on reduced VAT rates for electronically supplied publications

The EU Commission has launched a consultation on reduced VAT rates for electronically supplied publications. The consultation aims at obtaining the views of all stakeholders on the VAT treatment of electronically supplied publications (e-publications). Under current rules, e-publications must be taxed at the standard VAT rate, whereas for printed publications...

The Office of Tax Simplification (OTS) has published a consultation on look-through taxation

This paper further develops the look-through taxation model that was raised during the OTS’s small company taxation review.   Documents  Look-through discussion document

19 July 2016

New ministerial appointment July 2016: Chancellor of the Exchequer plus other appointments and departures

Philip Hammond is the new Chancellor of the Exchequer following Theresa May's appointment as Prime Minister. Details of other ministerial appointments are also detailed below.  The Queen has been pleased to approve the appointment of Rt Hon Philip Hammond MP as Chancellor of the Exchequer, David Gauke MP as Chief...

Consultation on the Scottish Government response to the introduction of the UK Apprenticeship Levy

This consultation asks for views on options for the use of its share of UK Apprenticeship Levy funding being transferred to the Scottish Government. The consultation runs from 13 July to 26 August 2016.  Click here to download a copy of the consultation paper.

14 July 2016

Finance Bill 2016: Public Bill Committee concluded - 7 July

On 7 July, the Public Bill Committee completed its consideration of the Bill, agreeing amendments to Clause 117 (SDLT higher rates for additional dwellings), new clauses 7, 8 and 9 (withholding tax on royalties), and new clauses 11-17 (transactions in UK land). The date for Report Stage in the House...

12 July 2016

Immediate tax impact from Brexit?

By Mike Seaton PE backed businesses are typically international and unless there has been care with loans provided to and from overseas entities denominated in overseas currencies, there will be forex (fx) movements arising on inter-company debt. With the recent 10% weakening of sterling against Euros and dollars, if the...

11 July 2016

Indirect tax implications of a Brexit vote on excise duties

By Martin Blanche and Johnathan C Davies Here is another post in a series blogs around the indirect tax implications of a Brexit vote, this time we are focusing on excise duties. In the UK, excise duties are assessed at rates determined by the UK government. For this reason, there...

European Commission proposes anti-money-laundering directive amendments

The European Commission has adopted a proposal to amend the fourth anti-money-laundering directive, forming part of the action plan against terrorist financing announced in February 2016. The proposals include full public access to beneficial ownership registers, interconnection of the registers, and extended due diligence powers. Member states are expected to...