Budget 2017 – highlights and (more) lowlights!

Here is a summary of all the Budget 2017 proposals affecting mainly small and mediums sized businesses and private clients: Corporation tax: Offshore property developers: all profits arising on or after 8 March 2017 from trading in and developing land in the UK will be taxed in the UK. Substantial Shareholding Exemption:   new rules will […]

UK Tax Residence – The Statutory Test

Tax residency in the UK has long been a highly contentious issue particularly for those with tax affairs in more than one jurisdiction. As there was no statutory definition of what makes a person a ‘resident’, often it was left to individual circumstances, general practice, judicial interpretations and at times even pure ‘common sense’! The […]

Controlled Foreign Company (CFC) Rules – Part I

The Finance Act 2012 (FA 2012) – Schedule 20 effectively changed the course for CFC rules by inserting a new Part 9A in to the Taxation (International and Other Provisions) Act (TIOPA) 2010. The new rules apply to accounting periods of a CFC commencing on or after 1 January 2013. In a series of articles […]

Taxation – Non-domiciled UK residents

Unlike some other tax jurisdictions, residence, ordinary residence and domicile status assume considerable significance when it comes to an individual’s liability to UK tax. UK residents not domiciled in the UK (‘non-doms’ for short) are treated to some special rules on their overseas income and gains. Whilst the Finance Act 2008 (FA 2008) fundamentally changed […]

Reasonable excuse and HMRC

HMRC defines a ‘reasonable excuse’ as some unexpected or unusual event beyond your control and provides a few examples on its website such as: a) a failure in the HMRC computer system, b) taxpayer’s computer breaking down before or during the preparation of the online return, c) a serious illness making the taxpayer incapable of […]