As announced in July of last year, the 2020 Budget introduces a new deferred payment plan option for Corporation Tax charged on profits or gains arising from certain transactions between UK companies and EEA companies of the same group of companies. The new rules will allow the deferral of CT over a period of up to 5 years, and has effect from 11 July 2019 for transactions occurring in accounting periods ending on or after 10 October 2018. The new measures follow the FTT decision in Gallaher to the effect that the absence of a deferral option was in breach of EU law and the option could not be read into the legislation.
The new powers tackling promoters of avoidance schemes
Under new proposals in draft Finance Bill 2021, HMRC will have wider information powers and be able to impose tougher sanctions on those who continue to promote or enable tax avoidance schemes. Whilst a robust approach to tackle unacceptable behaviour by a minority of promoters is entirely welcome, the new rules would arguably impose unnecessary administrative burdens on those operating within the law.
Draft Finance Bill 2020–21—promoters and enablers of tax avoidance schemes
Helen McGhee, senior associate at Joseph Hage Aaronson LLP, shares her insights on the Draft Finance Bill 2020–21 and its impact on promoters and enablers of tax avoidance schemes.
Apple and Ireland Win €13bn State Aid Appeal
The General Court of the European Union has today annulled the Commission’s decision regarding two Irish tax rulings in favour of Apple. The Commission had considered that the two rulings constituted State Aid, granting Apple €13bn in unlawful tax advantages.
The Price of Property
Helen McGhee looks at the present state of UK tax rules that must be considered when owning and disposing of UK property.
Inheritance tax problems in Finance Bill 2020
The rules on excluded property trusts are due to change with effect from royal assent. These changes are complex, and the new rules can have an unexpected and retroactive effect. Emma Chamberlain explores these rules to determine whether it may be necessary to exclude the settlor going forward as a beneficiary.