Possibly because of the retrospective introduction already of the reduced interest rate on HMRC judgment debts (8 July 2015) and the new 45% super tax on EU claims (21 October 2015) today’s PBR press notices contained no further announcements impacting claims enforcing EU rights or cross border transactions other than those already announced.
The announcements that the Chancellor did make this afternoon appear to be largely uncontroversial in tax terms. He has announced:
This article appears in the JHA November 2015 Tax Newsletter, which also features:
- a new 60% penalty to be charged in all cases successfully tackled under the GAAR
- anti-avoidance legislation in connection with the use of certain options to avoid stamp tax
- higher rates of SDLT on purchases of second homes and buy to let properties, and
- a requirement (from April 2019) that CGT on a disposal of residential property should be paid, on account, 30 days after the relevant disposal. It is unclear how this proposal would take account of, for example, available losses or the annual exempt amount.
- Judicial Reviews commenced against the new retrospective 45% rate of Corporation Tax to be applied to EU Claims
- Austrian Goodwill amortisation regime contrary to EU law
- Council approves the automatic exchange of cross-border tax rulings and APAs
- European Commission finds that Luxembourg and the Netherlands granted illegal State Aid to Fiat and Starbucks
