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12 February 2016

Are you ready to publicly disclose?

By Dipan Shah, Matt Timmons, Natalie Martin and Tracy Plimmer UK companies and LLPs face new rules to publicly disclose ownership and control, from 6 April 2016. New disclosure rules come into force from 6 April 2016 where all UK Companies and LLPs will be required to maintain and disclose...

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Overview HMRC has recently withdrawn a substantial number of Accelerated Payment Notices (APNs) and Partner Payment Notices (PPNs), which it had previously issued to taxpayers.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...

28 September 2015

BEPS: The final countdown

By Mike Cooper The culmination of the OECD’s BEPS action plan is nearly upon us. On 8 October, the G20 Finance Ministers will meet in Lima, Peru and be presented with the BEPS 2015 deliverables. The OECD has also confirmed that the complete "final BEPS package” will be published on...

24 September 2015

Make sure you’re part of the trust and transparency agenda

By Matt Timmons The Small Business, Enterprise and Employment Act (SBBE) received Royal Assent on 26 March 2015. The Act makes a number of significant changes to company law, and from April 2016 UK incorporated companies and LLPs will be required to maintain a register of persons of significant control...

17 September 2015

Everything you need to know about Patent Box (almost)

By Angela Browning and Adrian Gregory Hopefully you’re all back from holiday rested and recharged – which is good news, because if your company is affected by the BEPS actions affecting IP, and by patent box in particular, there’s plenty to do. The regime will undergo significant change over the...

04 September 2015

What will international tax become?

By John Steveni A couple of months ago I wrote about how the international tax system currently taxes digital, global business. I’ve talked a lot of about the issues – but what about the solutions? The OECD is putting its considerable resources behind the same conundrum with its Base Erosion...

27 August 2015

Ten years of Paying Taxes; ten years of simplifying tax compliance

By Andrew Packman, Neville Howlett and Tom Dane In the run up to the release of the 10th edition of Paying Taxes in November 2015, a chapter on the study’s purpose, methodology and results to date has been included a new book called “Tax Simplification” published in August of this...

11 August 2015

Addressing transparency in an ever changing tax landscape

By Stuart MacPherson Tax transparency is of increasing importance for multinational organisations, and is no longer just an issue for the Head of Tax to deal with. As the Organisation for Economic Co-operation and Development (OECD) introduces transfer pricing (TP) documentation reporting requirements as part of greater transparency initiatives globally,...

09 July 2015

Summer Budget 2015: Keeping the UK a competitive place to do business

Follow @PwC_UK for up to date Budget news #SummerBudget By Stella Amiss So George Osborne delivered his first Conservative Government Budget yesterday and it was stuffed full of new measures in an attempt to make his mark as a Chancellor with a 'big plan'. I hope you found our coverage...

08 July 2015

Budget: Impact of interest relief withdrawals on buy-to-let property

By Robert Walker Today's changes do nothing to address the fundamental lack of supply in the UK housing market and ultimately may backfire and hit people who are having to rent. We could see buy-to-let investors feeling the squeeze and putting up rents. This would have a major impact on...

Budget: Insurance Premium tax increases from 6% to 9.5%

By Ben Flockton and Naomi Saragoussi Increasing the basic rate of IPT from 6% to 9.5% will clearly not be welcomed by insurers. It will add over £12 to the average buildings and contents policy and over £13 to the average annual motor insurance bill. Insurers will also be concerned...

Budget: Chancellor smooths pace of spending cuts but still a lot of pain to come

By John Hawksworth and Andrew Sentance New projections by the OBR show that public borrowing will be lower than expected this year, but will then fall more slowly over the next three years as the Chancellor has smoothed the previous rollercoaster path of planned spending cuts. The total amount of...

Budget: Tax rises for private equity

By Alex Henderson The changes to the taxation of private equity carried interest bring to an end a basis of taxation agreed with HMRC as long ago as 1987 when the industry was in its infancy. This is one of a series of changes that have affected the way the...

Budget: Entrepreneurs lose out from changes to tax on dividends

By Alex Henderson The changes to the taxation of dividends remove the final vestiges of the system introduced in the early 70's where a credit was given for tax paid by the company. The system aimed to relieve the impact of the double taxation of companies and shareholders on distributed...

Budget: Chancellor's Annual Investment Allowance business boost and 'Decentralisation Nation' efforts

By Stephanie Hyde For companies across the UK, the prospect of the Annual Investment Allowance falling to £25,000 may have hamstrung investment and damaged the economy. Now the Chancellor has announced a ceiling of £200,000 it will take some of the pressure off small and medium-sized business when planning investment....

Budget: Changes for the financial services sector

By Matthew Barling and Colin Graham The reform and reduction in the bank levy will be welcomed particularly by those banks with large overseas operations. However, the long term phased nature of the reform coupled with the new profits based 8% corporation tax surcharge means that the overall tax burden...

Budget: Changes for non doms are a 'game changer'

By Alex Henderson The changes for non doms weren't unexpected after the attention they received in the Election campaign, but are a game changer for those affected. Non doms who have been in the UK since 2002 will come within the full UK tax regime in 2017. All their overseas...

Budget: Cut to corporation tax a bold move

By Stella Amiss The cut in corporation tax to 19% 2017-18, and 18% from 2020-2021 is a bold and surprise move. Business weren't calling for a further rate reduction, and it's expensive - £6.6bn over five years. But it sends a clear signal that the Government is pro tax competition...

07 July 2015

Are you ready for the Summer Budget?

Follow @PwC_UK for up to date Budget news #SummerBudget By Stella Amiss Tomorrow’s Summer Budget is the first real opportunity for the Chancellor to put his mark on the nation's finances, unconstrained by coalition negotiations. This is the time to set any major reforms in train so they can bed...

02 July 2015

Trends in Tax Transparency

By Janet Kerr Who in your organisation has an interest in tax transparency and has spent some time over the last year thinking about your public tax disclosures? The answer to this question lies increasingly outside the tax department, a response to greater scrutiny on tax from external stakeholders. Boards,...

19 June 2015

Digital and tax: location, location, location

By John Steveni A couple of weeks ago, I wrote about the challenges of adapting the international tax regime to the digital age. One of the biggest issues that will have to be tackled is around the location of income. As I previously said, the current tax regime dates largely...

27 May 2015

Diverted Profits Tax – what does it mean for you?

By Nick Woodford Diverted Profits Tax (DPT) has been with us now for almost two months and we’re really starting to see the impact that it is having on a wide range of companies. Last week the Australian Government announced that they will be doing something similar, which makes me...

12 February 2016

Update on the introduction of VAT in the GCC

By Christine O’Malley There has still been no formal announcement regarding the introduction of VAT though there has been speculation in the press in several countries and various comments from Government ministers. Various time lines have been suggested but we understand the position is as follows. We expect a formal...

11 February 2016

Act now to keep your bespoke scale rates for subsistence in the UK

By Jonathan Berger Tax legislation recognises that practical circumstances can vary widely, and for many years it has been open to all employers to ask HMRC to allow them to pay subsistence allowances at a level which is appropriate for their employees. However, in-line with the abolition of P11D Dispensations,...

The end of Dispensations and an update to HMRC's benchmark daily subsistence rates from 6 April 2016

By Jonathan Berger P11D Dispensations are to be phased out from 6th April 2016 and replaced with a statutory regime for paid and reimbursed expenses. Following this new ruling, HMRC has recently confirmed their expectations of the review and governance requirements for businesses “a checking system” and have published an...

Direct Recovery of Debts and vulnerable customers: HMRC briefing

New powers known as Direct Recovery of Debts (DRD) allows HM Revenue and Customs (HMRC) to recover tax and tax credit debts from people and businesses directly from their bank accounts. This paper sets out the criteria HMRC will use to identify vulnerable customers in relation to Direct recovery of...

10 February 2016

Factsheet on HMRC and multinational corporations

There has been considerable media coverage of the tax affairs of multinational corporations, particularly on the conclusion of HMRC’s enquiry into Google. The Public Accounts Committee is taking evidence on this issue on Thursday 11 February in Parliament. Ahead of this hearing, HMRC is setting out some facts to help...

09 February 2016

Changes to P11D dispensations

P11D Dispensations are to be phased out from 6th April 2016 to be replaced by a statutory regime for paid and reimbursed expenses. HMRC have recently confirmed more details about how the new approach will work. HMRC have updated their Employment Income Manual with details on how the replacement system...

Payrolling Benefits in Kind: draft guidance

HMRC has published draft guidance to help employers understand how to payroll benefits in kind. Employer guidance on calculating cash equivalents, pay periods, the taxable amounts for benefits in kind. Payrolling Benefits in Kind

Imports and exports to the UK continental shelf - are you ready for the change?

By Christine O’Malley New customs duty legislation is due to come into force from 1 May 2016 under the Union Customs Code (UCC) which will result in a number of changes from existing practices in the UK. What does it mean? One of the key areas of change will be...

08 February 2016

Revenue and Customs Brief 5 (2016): Tonnage Tax - qualifying ships and flagging

This HMRC brief explains if during financial year 2016 a company in Tonnage Tax starts to operate a ship that is not registered in a European Union or European Economic Area member state, then they must carry out a ‘flagging test’ to determine whether the ship qualifies for Tonnage Tax....

Public Accounts Committee holds a session on corporate tax deals on Thursday 11 February 2016 at 10.00am

Public Accounts Committee holds a session on corporate tax deals on Thursday 11 February 2016 at 10.00am. Watch Parliament TV: Corporate Tax Deals

HM Treasury gives evidence on the Draft Finance Bill 2016

On 8 February 2016, the Finance Bill Sub-Committee hears evidence from officials from HMRC and HM Treasury as part of its ongoing inquiry into the Finance Bill 2016. This is the final evidence of the inquiry. Parliament TV: Draft Finance Bill 2016 Inquiry: Draft Finance Bill Sub-Committee Economic Affairs Finance...

05 February 2016

Alcohol Wholesaler Registration Scheme – 7 weeks to register!

By Christine O’Malley To combat duty evasion on alcoholic beverages, HMRC has introduced the Alcohol Wholesaler Registration Scheme (“AWRS”) from 1 January 2016. Following consultation, details of the scheme have now been published in the Finance Bill 2015 and subsequently HMRC Notice 2002. Please use the following link to see...

Increase cost of customs duty on royalties - will you be affected?

By Christine O’Malley The Union Customs Code (UCC), effective from 1 May 2016, will fundamentally change the duty treatment of royalty payments. For affected businesses this could result in significant annual customs duty increases amounting, in some cases, to several millions of pounds. In addition to the increase in non-recoverable...

04 February 2016

New HMRC avoidance spotlight: Employee Bonus Schemes

HMRC is aware of a number of tax avoidance schemes, based on contracts for difference, that are being used by some businesses to provide tax free or tax reduced rewards to their employees. One such scheme is known as the Growth Securities Ownership Plan. Employee Bonus Schemes - Growth Securities...

Revenue and Customs Brief 7 (2016): reminder of withdrawal of the VAT Misdirection Extra Statutory Concession 3.5 in cases of VAT liability change

This brief is issued as a reminder that the misdirection class concession no longer exists. Document Revenue and Customs Brief 7 (2016): reminder of withdrawal of the VAT Misdirection Extra Statutory Concession 3.5 in cases of VAT liability change Detail This brief also gives notice that with effect from 1...

Residential property occupied by employees was not "taxable property" for a pension fund: FTT J&A Young (Leicester) Limited & others

The First-tier tribunal has found that where a pension fund acquired a residential property for the purpose of providing accommodation for foreign workers working in the nearby premises and was used solely for that purpose, this was sufficient for it to be excluded from the definition of taxable property and...

03 February 2016

Treasury Select Committee launches enquiry into the UK's tax policy and tax base

The Treasury Select Committee has launched an enquiry into UK tax policy and the tax base addressing in particular the following: 1)The making of tax policy; 2) The problem of the shrinking tax base; 3) Radical solutions to the problem of the shrinking tax base; 4) Other mitigations of the...

Disclosure of Tax Avoidance Schemes: hallmark regulations - summary of responses and next steps

Summary of response on draft changes to the existing Disclosure of Tax Avoidance Schemes (DOTAS) hallmark regulations along with draft regulations for a new financial products hallmark. Disclosure of Tax Avoidance Schemes: hallmark regulations - summary of responses and next steps The government consulted in 2015 on draft changes to...

Domicile: Income Tax and Capital Gains Tax - consultation

This legislation will deem certain persons, who would otherwise be non-domiciled in the UK as a matter of general law, to be domiciled here for the purposes of Income Tax and Capital Gains Tax. Comments should be received by 2 March 2016. This legislation applies to individuals who are currently...

Shares and assets valuation announces withdrawal of informal post transaction valuation checks services

HMRC's shares and asset valuation (SAV’s) resources are being severely stretched and the decision has been taken to withdraw the valuation check service that it has previously offered on an informal basis, for the purposes of PAYE Health Checks and ITEPA Post Transaction Valuation Checks. Both these categories of check...

Another record breaking year for Self Assessment

The number of Self Assessment returns completed on time once again breaks records with over 10 million submitted online. HM Revenue and Customs has revealed that 10.39 million Self Assessment tax returns were completed ahead of the 31 January deadline; that’s over 92% of the total returns expected, and 150,000...

Corporate taxation: Commission to discuss its plans for fairer taxes with MEPs

Corporate tax avoidance costs EU countries €50-70 billion in lost revenue a year, according to the European Commission. On 2 February it will discuss with MEPs how it plans to make corporate taxation fairer and more efficient. The European Parliament has set up two special committees to investigate and called...

02 February 2016

What does CBCR mean for you? Five key questions companies need to address now

The much publicised signing ceremony for the Multilateral Competent Authority Announcement (MCAA) at the OECD was another landmark in the implementation of Country by Country Reporting (CBCR) as a tax risk assessment tool for Tax Authorities globally. It feels like a long time since the UK led the way by...

01 February 2016

Upper Tier Tribunal finds settlement payment not deductible as expense of partner's trade

The Upper Tier Tribunal has rejected the First Tier Tribunal's decision and found that an individual who was a member of an LLP law firm was not entitled to a deduction from trading income for a settlement payment in connection with his former membership of a different LLP. The case...

PAC session on corporate tax deals to be held on 11 February

The Public Accounts Committee has launched a new inquiry into corporate tax deals. It will hold the first session, of the inquiry, with Google and HMRC on 11 February 2016. PAC inquiry Corporate Tax Deals inquiry Inquiry status: open Public Accounts Committee holds a session on corporate tax deals on...

IFS chapter on corporation tax avoidance and BEPS for Green Budget 2016

The IFS has published a chapter for the material to support its coming Green Budget event on 8 February 2016 on 'Corporate tax avoidance: tackling Base Erosion and Profit Shifting'. It explains many of the concepts behind BEPS, what the OECD-led recommendations are, what choices they give the UK and...

28 January 2016

Automatic enrolment: technical changes consultation

This is a consultation on proposed technical changes intended to simplify the automatic enrolment process and reduce burdens on employers. Automatic enrolment: technical changes This consultation closes at 16 February 2016 11:45pm This is a consultation on proposed technical changes intended to simplify the automatic enrolment process and reduce burdens...

HMRC: Customs vision for 2020

HMRC has set out its strategic plan for the UK customs service in support of international trade for the period until 2020. This will include implementing the EU's new Union Customs Code from May 2016, and replacing a number of digital systems for customs processes during 2017. HMRC expects international...

Signing ceremony on Wednesday 27 January 2016 to mark major milestone towards implementation of OECD/G20 BEPS Project

Ministers and top tax officials from more than 30 countries will sign an international agreement at the OECD on Wednesday 27 January 2016 that will significantly advance the fight against corporate tax avoidance. OECD Secretary-General Angel Gurría and French Finance Minister Michel Sapin will brief the media at 17:00 at...

Andrew Bailey appointed as new Chief Executive of the FCA

HM Treasury have announced the appointment of Andrew Bailey as the new permanent Chief Executive of the Financial Conduct Authority (FCA). Andrew is currently the Deputy Governor for Prudential Regulation at the Bank of England and Chief Executive Officer of the Prudential Regulation Authority. Andrew is expected to take up...

Employment Allowance: excluded companies

This tax information and impact note will restrict eligibility for the Employment Allowance so that limited companies with a single director, and no other employees, will not be able to benefit from the allowance from 6 April 2016. This measure was announced in Summer Budget 2015, for implementation from 6...

Employment Allowance: increase to £3,000

The National Insurance contributions (NICs) Employment Allowance was introduced in April 2014, for the purpose of supporting businesses and charities in helping them to grow by cutting the cost of employment. Eligible employers can claim the allowance, which reduces their Employer NICs bill by up to £2,000 a year. This...

UK/Kosovo: new Double Taxation Convention

A new Convention between the UK and the Republic of Kosovo for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital was presented to Parliament in January 2016. Treaty Series No.7 (2016) web version Treaty Series No.7 (2016) print...

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...

25 January 2016

EC publishes responses to its corporate tax transparency consultation

The European Commission has published a summary of the responses received to its consultation on options for requiring further disclosure of corporate tax information at EU level. Full Text http://ec.europa.eu/finance/consultations/2015/further-corporate-tax-transparency/index_en.htm The consultation proposals, based around country-by-country reporting and paying taxes where profits are made, form part of the EU's Action...

Government responds to PAC reports

Government departments have responded to the Public Accounts Committee reports through a Treasury minute. This includes the response to the report on HMRC's performance in 2014/15. Treasury minutes Treasury minutes: January 2016 Download 53532_Cm_9190_Accessible Treasury minutes: January 2016 (print)

21 January 2016

UK/Germany Double Taxation Convention - amending Protocol in force 29 December 2015

The Protocol amending the UK/Germany Double Taxation Convention, signed on 17 March 2014, entered into force on 29 December 2105. It has effect in Germany from January 2016 and in the UK from April 2016. www.gov.uk/government/publications/germany-tax-treaties-in-force Signed on 17 March 2014 This Protocol entered into force on 29 December 2015....

UK/Bulgaria: Convention for the avoidance of double taxation

Convention between the UK and the Republic of Bulgaria for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital Gains. Presented to Parliament, January 2016. Presented to Parliament January 2016 Documents Treaty Series No.6 (2016) web version Treaty Series No.6 (2016) print version Please click...

Early exit charges to be capped as Chancellor takes action on pension barriers

Excessive charges for accessing a pension pot early will be brought to an end. The Chancellor George Osborne (Tuesday 19 January) announced an end to prohibitive charges faced by people looking to access their pension pot as he outlined proposals to place a duty on the Financial Conduct Authority (FCA)...

Government response to VAT in the digital single market: EU consultation

The UK government's response to a European Commission consultation on modernising VAT for cross-border e-commerce. UK government response to EU consultation on modernising VAT for cross-border e-commerce This document sets out the government’s response to the European Commission’s consultation on simplifying VAT payments on cross-border e-commerce transactions in the EU.