JHA LLP | London Tax Disputes Solicitors & Barristers

Autumn Statement 2016 – views from the market

28 November 2016

Author: Steve Bousher, Helen McGhee

Originally published in Lexis®PSL Tax Analysis on 28 November 2016.

It seems that the proverbial white rabbit was the announcement of the single annual fiscal event. After the Spring Budget next year and the consequent Summer Finance Bill, from Autumn 2017 the Budget and Finance Bill cycle will move to the Autumn. Draft clauses for the next finance bill will be published in the Summer. This should allow longer and better debate before the clauses are enacted. There will still be a Spring Statement (from Spring 2018) in response to the OBR’s Spring forecast but normally the government would not use that Spring Statement to announce tax changes. The Chancellor intends that changes to the tax system should be announced in the Autumn. On balance this looks to be an improvement to the system and the CIOT and the IFS called for this change in an open letter back in September.

Continue reading on Lexis®PSL Tax Analysis (subscription required)

Or access the complete article in PDF format

Return to List of Articles by UK Lawyers on Tax Disputes, Tax Litigation, HMRC Tax Appeal

Return to Listings

Left Button on Tax Dispute & Tax Litigation Lawyers in London

Our Insights

Insights from UK Tax Dispute Lawyers & HMRC Tax litigation

Search and Seizure

Helen McGhee TEP, Elizabeth Dean and Megan Durnford consider HMRC’s ever-expanding criminal investigation powers

UT considers taxpayer’s application for permanent anonymity and third-party disclosure request (HMRC v The Taxpayer and Others)

The Upper Tribunal (UT) rejected a taxpayer’s application for permanent anonymity, following the taxpayer's decision to withdraw their substantive appeal with the First-tier Tax Tribunal (FTT). The UT further granted a third party limited access to the FTT’s previous case management decision. The UT’s decision emphasises the importance placed on open justice and highlights the court and tribunals’ reluctance to permit anonymity in litigation.

PRIVATE CIENT BUDGET UPDATE

The new rules are complex and what follows is an overview. The non dom changes will be effective from 6 April 2025. No changes have been made to the statutory residence test (SRT) effective for UK tax purposes from tax year 2013/14 onwards (prior to then the common law determined UK residence status for tax purposes).

THE END OF THE REMITTANCE BASIS AND THE TWO TRANSITIONAL PROVISIONS

Tax year 2024/25 (the current year) marks the last year that eligible individuals will be able to make a remittance basis claim. From 2025/26 the remittance basis will be replaced with the 4-year FIG regime. There is no amnesty for existing foreign income and gains that were previously sheltered by the remittance basis regime and have not yet been taxed. Any remittance to the UK after 5 April 2025 will be subject to taxation just as it was before, albeit the new legislation:

REVIEW OF ANTI-AVOIDANCE LEGISLATION

A 29 July 2024 government policy paper announced that there would be a review of the offshore anti-avoidance legislation.

Right Button on Tax Dispute & Tax Litigation Lawyers in London

View Our Insights