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1 month ago | 
mondaq.com | Mark Hunter |Sarah Ling |Clare Wilson
M Macfarlanes More We are a distinctive law firm, combining expertise, agility, and a client-centric culture to address the most challenging legal demands and foster innovation. Our firm is structured around the needs of our clients, with whom we build long-lasting relationships, tackling complex issues in key practice areas. Our approach is focused and deliberate.
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1 month ago | 
lexology.com | Mark Hunter |Sarah Ling |Clare Wilson
In their current form, agricultural property relief (APR) and business property relief (BPR) provide relief from inheritance tax (either at 50% or 100%) in respect of eligible business or agricultural property.
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Nov 14, 2024 | 
taxjournal.com | Sarah Ling |Andrew Marr |Julian Feiner |Mike Lane
In Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 (TC) (1 November) the First-tier Tribunal (FTT) dismissed Syngenta Holdings Ltd’s (SHL) appeal against closure notices denying corporation tax deductions for loan interest on the basis that SHL was party to the loan for an unallowable purpose. The context was that SHL acquired the entire issued share capital of its sister company Syngenta Ltd (SL) from its immediate parent company Syngenta Alpha BV (SABV).
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
It may be remembered that in 2021 some proposals were floated for the UK to introduces some redomiciliation rules so that foreign companies can change their place of incorporation to the UK, and with it the governing law of the company. This would be very welcome, and would correspond to the rules in many other countries. However, anybody hoping to take advantage of this change better not hold their breath because it is certainly not going to happen any time soon.
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
The Finance Act 2021 (Schedule 26 Second Penalty Assessments) (Appointed Day: Regulation Making Power) Regulations SI 2024/1132 bring FA 2021 Sch 26 into force on 12 November 2024 but only for the purposes of making regulations under para 16(2) of that Schedule. Schedule 26 introduces a new two-tier late-payment penalty system under the making tax digital regime – escalating the penalty the longer the amount remains outstanding from the payment date.
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
Rachel Reeves’ first Budget introduced a number of significant changes to IHT. In summary:The freeze to the IHT thresholds has been extended to 2030 meaning the nil rate band remains at £325,000 and the residence nil rate band at £175,000. The nil rate band threshold has been static since 2009 and the freeze means that more individuals fall into the IHT net each year with inflation, particularly in house prices. Inherited pensions will be subject to IHT from April 2027.
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Nov 13, 2024 | &sz=64)
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
HMRC are to update their interest rates for late payments and overpayments of most taxes following the recent Bank of England decision to reduce the base rate to 4.75%. Based on the existing method for calculating the HMRC rates (as provided by SI 1989/1297) the following will apply from 26 November 2024 (except for quarterly instalment payments of corporation tax):late-payment interest: 7.25%;repayment interest: 3.75%.
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
The Government published the Finance Bill on 7 November 2024. With 84 substantive clauses and 13 Schedules running to 272 pages a large portion of the Bill is devoted to the replacement of the remittance basis for non-domiciled individuals. Part 2 ‘replacement of the rules relating to domicile’ (sections 21 and 37–46 and Schedules 8–13) takes up 110 pages (i.e. 40%) of the Bill.
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Nov 13, 2024 | 
taxjournal.com | Peter Vaines |Ray McCann |Sarah Ling |Andrew Marr
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