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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...

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...

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...

From April 2018, Land Transaction Tax (LTT) will replace UK Stamp Duty Land Tax (SDLT) in Wales

Like SDLT, LTT is payable when you buy or lease a building or land over a certain price. It may affect house buyers and sellers and businesses including builders, property developers and agents involved in the transaction process (such as solicitors and conveyancers). The legislation will broadly be consistent with...

Consultation: Evolving National Employment Savings Trust (NEST) to respond to the changing pensions landscape

Since the establishment of NEST, the pensions landscape has changed. With the introduction of automatic enrolment, there has been a move towards mass-market defined contribution pensions, and the government has made changes to how people can access their pension savings. This call for evidence seeks views on how NEST might...

06 July 2016

EU Commission sets out next steps to increase tax transparency and tacke tax abuse

The Commission recently set out the next steps in its campaign to boost tax transparency in order to fight tax evasion and avoidance in the EU, taking into account the problems highlighted in the recent media leaks known as the Panama Papers.  European Commission press release

Taxing profits from trading in and developing UK land

Legislation for Finance Bill 2016 was tabled in the Public Bill Committee on 5 July 2016 (new clauses 11 to 17) and takes effect from that date. This introduces new rules to tax companies' trading profits derived from land in the UK, regardless of where a company is resident and...

EIOPA consults on policy proposals regarding the implementation of the Insurance Distribution Directive

The European Insurance and Occupational Pensions Authority (EIOPA) has recently published a Consultation Paper on its draft technical advice to the European Commission on possible delegated acts concerning the Insurance Distribution Directive (IDD). EIOPA's draft technical advice pursues three high-level objectives: 1) First, to ensure that, throughout the product lifecycle,...

OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and revised guidance on profit splits

The OECD is consulting on two discussion drafts: 1) Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; and 2) Revised Guidance on Profit Splits, which deals with work in relation...

OECD seeks public review of BEPS conforming changes to Chapter IX of the OECD Transfer Pricing Guidelines

Interested parties are invited to review the conforming changes to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings." Deadline for comments is 16 August 2016.  See: http://www.oecd.org/tax/beps/public-review-sought-of-beps-conforming-changes-to-chapter-ix-of-the-oecd-transfer-pricing-guidelines.htm

Indirect Tax implications of a Brexit vote on customs 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 customs duties. There may be a period of uncertainty ahead for UK traders – both manufacturers and importers of goods....

04 July 2016

The surge in FinTech start-ups – but are they pursuing all the R&D funding available?

The growth of the FinTech sector is exceeding all predictions and continues to play an influential role in the Financial Services industry, driving innovation and threatening to disrupt existing, well established businesses. According to the recent PwC global Fintech survey, funding of FinTech start-ups more than doubled in 2015 reaching...

01 July 2016

First meeting of OECD's new inclusive framework to tackle BEPs marks a new era in international tax co-operation

Representatives of more than 80 countries and jurisdictions have gathered in Kyoto, Japan to push forward ongoing efforts to update international tax rules for the 21st century, the latest step in the OECD/ G20 Project to tackle Base Erosion and Profit Shifting (BEPS).   OECD news release

Update to Venture Capital Schemes Manual - HMRC request comments

HMRC welcomes comments on their new guidance in relation to the Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCTs). HMRC will incorporate comments received by 31 August 2016 in the next version of this guidance.   Introduction to the changes  https://www.gov.uk/hmrc-internal-manuals/venture-capital-schemes-manual/8010

Business Secretary to chair government group focused on business engagement following referendum

A new business engagement inter-ministerial group bringing together ministers from across government has recently been established. It will be chaired by the Business Secretary Sajid Javid. The new group, which will meet next week, will provide an opportunity for ministers to discuss the views, thoughts and concerns from businesses of...

Indirect Tax implications of a Brexit vote and the EU law

By Martin Blanche and Johnathan C Davies The wider emotional, political and economic outcomes of the referendum vote to leave the EU are still being worked through, but what as indirect tax practitioners, can we do to prepare ourselves and our businesses for this? The slightly frustrating answer is that...

30 June 2016

MEPs call for swift Brexit to end uncertainty and for deep EU reform

In a resolution voted after an extraordinary plenary debate on Tuesday 28 June, the European Parliament has said that the UK must respect the wish of a majority of its citizens, entirely, fully and as soon as possible, by officially withdrawing from the EU before any new relationship arrangements can...

Finance Bill 2016: Proposed government amendments - Public Bill Committee

The government has tabled a large group of amendments to be considered by the Public Bill Committee, beginning on a date to be announced.  www.gov.uk/government/publications/finance-bill-2016-public-bill-committee

OECD releases guidance on the implementation of country-by-country reporting

The OECD has taken a new step in its continuing efforts to boost transparency in international tax matters with the release of Guidance on the Implementation of Country-by-Country (CbC) Reporting.  OECD announcement

PM Commons statement on the European Council

Prime Minister David Cameron gave a statement in the House of Commons on the European Council attended on 28 June   See: https://www.gov.uk/government/speeches/pm-commons-statement-on-the-european-council-29-june-2016

29 June 2016

Large businesses - publishing tax strategy

HMRC has published an overview guide for large businesses (with a turnover above £200 million or balance sheet over £2 billion), on the requirement to publish their tax strategy before the end of the next financial year commencing after Royal Assent to Finance Bill 2016, and yearly thereafter.   www.gov.uk/guidance/large-businesses-publish-your-tax-strategy

Statement by the Chancellor following the EU referendum

Statement on 27 June 2016 by the Chancellor of the Exchequer, George Osborne following the outcome of the EU referendum.   See: https://www.gov.uk/government/speeches/statement-by-the-chancellor-following-the-eu-referendum  

Revenue and Customs Brief 11/2016: Transfer of a going concern and VAT groups following Intelligent Managed Services Limited judgment

In a change of policy, HMRC will now accept that the transfer of a business to a company in a VAT group can be the transfer of a going concern (TOGC) for VAT purposes, provided the company intends to operate the same kind of business in supplying services to other...

EU Parliament names “Panama Papers” inquiry committee members

The European Parliament has named the 65 members of its “Panama Papers” Committee of Inquiry into tax evasion and money laundering, after approving its remit on 8 June. The committee’s shorthand label will be “PANA”.   European Parliament press release

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