The government are concerned that a small number of businesses choose not to pay the tax they owe or seek to unfairly reduce their tax bill. One of the ways available to HMRC to tackle this is the power to require high-risk businesses to provide an upfront security deposit where there is a serious risk of non-compliance. Currently, these powers only apply to certain taxes and duties, but the non-compliant behaviours which warrant security action will be typically found across other aspects of these businesses’ tax affairs. Read more
Archive for Kevin Offer
The speed and scale of the changes caused by digitalisation have had implications for the UK tax system especially in respect of corporation tax, where the development of certain business models has challenged the understanding of how and where companies create value and ultimately how that value is taxed.
At the Autumn Budget 2017 the government set out its initial position on the issue underlining the principle which underpins the international corporate tax system that the profits of a business should be taxed in the countries in which value is created. The government were concerned that this principal was being challenged by certain digital businesses and the paper published in November 2017 sought to address that question, by assessing three possible challenges that have been put forward: Read more
Enterprise Investment Scheme and Seed Enterprise Investment Scheme relief are being considered by a large number of companies at the moment as a way of raising funds but at the same time enabling investors to obtain attractive income tax and capital gains tax reliefs.
A number of cases have been heard before the First tier and Upper Tribunals that demonstrate how easy it is to fall foul of the complex provisions granting these reliefs. Moreover, there have been a number of changes to the legislation in recent years, and more changes have been announced that will have a significant impact on the operation of the relief.
Risk To Capital Condition Read more
The realisation of intangible fixed assets (IFAs), contained in Ch 4, Part 8, CTA 2009, broadly expects the profit and loss on the disposal of the IFA to be computed by reference to the proceeds of realisation for accounting purposes. In an arm’s length cash transaction this would normally be the amount received subject to an arm’s length or market value adjustment.
For non-cash transactions involving the transfer of IFAs between related parties, the amount recognised on disposal should be equivalent to the cash that would be received in a market value transaction. Read more