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Oct 23, 2024 | 
taxjournal.com | Matthew Mortimer |Andrew Marr |Chris Etherington |Johan Barros
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Sep 20, 2023 | 
taxjournal.com | Matthew Mortimer |Heather Self |Damien Crossley |Tom Wallace
Multinational top-up tax: an overview © Copyright LexisNexis 2023. All rights reserved. 20 September 2023 Speed read Finance (No. 2) Act 2023 has now implemented the income inclusion rule aspects of the OECD’s Pillar Two model rules into UK tax law with effect for accounting periods beginning on or after 31 December 2023. Draft legislation for the UK’s implementation of the undertaxed profits rule aspects of those template rules has also recently been published.
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Apr 21, 2023 | 
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
Home >Articles > HMRC manual changes: 21 April 2023
HMRC manual changes: 21 April 2023
20 April 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Direct taxes Manual Page Comments Capital Gains Manual Updated: CG73997M, CG73998VArchived: CG73999P Link added to revised guidance, on the genuine diversity of ownership condition, in the Investment Funds Manual...
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Apr 21, 2023 | 
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
Home >Articles > Other cases that caught our eye: 21 April 2023
18 April 2023
UK taxation of a foreign dividend: In J Buckingham v HMRC [2023] UKFTT 358 (TC) (4 April 2023), the taxpayer held shares in the Dr Pepper Group, which was merged with another company using a Delaware special purpose vehicle. A special dividend was...
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Apr 19, 2023 | 
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
Home >Articles > Discounted gift schemes: valuation interest rate
Discounted gift schemes: valuation interest rate
19 April 2023
HMRC has increased the valuation rate of interest used to determine the value of retained rights under discounted gift schemes from 4.5% to 6.75% per annum with effect from 1 May 2023. highlights the importance of the change for providers of discounted gift schemes and those who give advice on the valuation of retained rights.
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Apr 19, 2023 | 
taxjournal.com | David Whiscombe |Philip Swinburn |Chris Etherington |Matthew Mortimer
No: of course we’re notweighing in on thattiff. This note is about the First-tier Tribunal case ([2023] UKFTT 340(TC)) on the tax treatment of the amounts which the BBC (and BT) paid to secureMr Lineker’s services. But, in its field, it’s likely to set the catamong the pigeons quite as much as anything Mr Lineker has tweeted.
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Apr 19, 2023 | 
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
Home >Articles > GAAR Panel gives opinion on SDLT scheme
GAAR Panel gives opinion on SDLT scheme
19 April 2023
The GAAR Advisory Panel has found that arrangements to minimise the SDLT payable on the purchase of a residential property were not reasonable. involved the purchase of a house by a married couple.
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Apr 19, 2023 | 
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
In one of the more high-profile IR35 cases involving well-known media personalities, Gary Lineker has scored a victory against HMRC in the First-tier Tribunal after Tribunal Judge Brooks found in his favour (G Lineker and another t/a Gary Lineker Media v HMRC [2023] UKFTT 340 (TC), reported in last week’s edition).
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Apr 19, 2023 | -bill-commons-passes-pillar-2-amendments&sz=64)
taxjournal.com | Philip Swinburn |Chris Etherington |David Whiscombe |Matthew Mortimer
The following government amendments were passed in the House of Commons on 18 April 2023 at Committee of the Whole House stage:R&D tax relief schemes:Sch 1 (govt amendment 14): this amendment updates CTA 2009 s 1057 to allow a company to make a valid R&D claim where it has transferred its trade to another group member and, as a result of that transfer, would not otherwise satisfy the requirement to be a going concern.
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Apr 19, 2023 | 
taxjournal.com | Chris Etherington |Philip Swinburn |David Whiscombe |Matthew Mortimer
When an employee or director receives a loan from their employer, this can represent a taxable benefit if it is considered a cheap or interest-free loan. Cheap for this purpose means that the interest rate charged by the employer on the loan is below the official rate of interest set by government. In 2022/23, HMRC’s official rate of interest on such ‘beneficial loans’ was 2.0%.
