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LATEST NEWS
Provisional treaty relief scheme renamed
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
Pro bodies clarify trustee residence
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
Change in IHT approach to domicile status
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
EC consults on cross-border interest
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
Online 'conduits' not VAT-exempt
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
'Just pay’ demands omit contact details
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
Red tape burden on rise, claim companies
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
Online 'conduits' not VAT-exempt
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
Carbon trading rules given brief regard
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
Longer turnaround for paper 64-8s
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Carbon trading rules given brief regard
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
Online trusts filing 'will improve accuracy'
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
'Just pay’ demands omit contact details
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
Longer turnaround for paper 64-8s
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Carbon trading rules given brief regard
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
HMRC have published Revenue & Customs Brief 35/10, to cover the draft legislation and guidance on how the reverse charge for emissions allowances, to come into effect from 1 November, will operate. The reverse charge accounting mechanism for businesses trading in emissions allowances will apply to: read more
Online trusts filing 'will improve accuracy'
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
Provisional treaty relief scheme renamed
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
Pro bodies clarify trustee residence
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
Factsheets aim to help with compliance
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
Red tape burden on rise, claim companies
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
EC consults on cross-border interest
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
Change in IHT approach to domicile status
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
Pensions overhaul 'needs more work'
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
Pensions overhaul 'needs more work'
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
Factsheets aim to help with compliance
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
Online 'conduits' not VAT-exempt
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
Following the judgment of the Court of Appeal in Insurancewide and Trader Media Group, HMRC have published Revenue & Customs Brief 31/10. The two companies provided click-through services from their websites to the sites of insurers, brokers and similar firms. The court found that the companies were insurance intermediaries for the purposes of the VAT exemption and an act of introduction, with no further involvement in the intermediation of the contract of insurance, qualified for exemption as an insurance related service. The brief explains that HMRC now accept that insurance introductory services will be exempt from VAT only when a provider is doing much more than acting as a ‘mere conduit’ through which a potential customer is passed to a provider.
'Just pay’ demands omit contact details
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
HMRC are demanding payments from taxpayers via letters that deliberately include no contact details. Taxpayer are provided with no address or phone number to use if they wish to dispute the amount with the department, which refers to the written correspondences as ‘just pay’ letters and says ‘they are used on low-value, high-volume debts where the use of people-resources to chase would not be efficient’. Taxation has seen a ‘just pay’ demand sent earlier this month to a company in response to an allegedly unpaid PAYE liability of £120 from 2006-07. It provides details of a link on the Revenue’s website for making payments and threatens legal action, including the seizure and sale of goods or bankruptcy, if payment is not made. read more
Longer turnaround for paper 64-8s
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Turnaround times for paper forms handled by HMRC's central agent authorisation team will be extended until 31 October, the department has warned. The longer waiting period are as a result of the taxman having 'redeployed resources to higher priority work’. The Revenue has urged agents to use online agent authorisation, which will not be affected. However, agents should not use the online process to set up a client authorisation if they have already submitted a form 64-8 for the same client. Doing so will cause problems with HMRC systems and may delay the authorisation process further. The department says it will continue to give priority to paper authorisations for self assessment. The expected turnaround times are:read more
Online trusts filing 'will improve accuracy'
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
The latest issue of HMRC’s newsletter for trusts and estates practitioners has been published. Since 1 July, the Revenue has processed internet-filed returns using a new, automated system, which will be able to deal with all online returns from 2009/10 and subsequent years. HMRC say the new system will:read more
Red tape burden on rise, claim companies
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
Tax-related red tape is increasing, making the UK a less appealing country in which to do business, according to large firms. A poll taken on behalf of the Revenue found that 64% of companies surveyed believe the administrative burden of tax compliance has risen over the past 12 months, while at the same time HMRC have become less transparent in their decision-making. Almost one-third of large companies (30%) said the perceived surge in Revenue bureaucracy had a negative effect on the UK’s competitiveness, and around one in five (18%) claimed they had considered relocating all or part of their organisation abroad to a country with less burdensome tax system. ‘If only a small fraction of those companies that have considered relocating did relocate abroad it would decimate the UK’s tax revenues,’ warned Roy Maugham, tax partner with accountancy group UHY Hacker Young. read more
Provisional treaty relief scheme renamed
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
Following changes in 2007 to HMRC's double tax (DT) treaty relief processes and the introduction of the DT treaty passport scheme, effective from today, the one-to-one loan aspect of the provisional treaty relief scheme (PTRS) is no longer needed. It has therefore been discontinued. The part of the PTRS dealing with syndicated loans has been retained under the name syndicated loan scheme (SLS). This enables DT treaty relief to be given from withholding tax, which is deductible on UK source interest paid to the lending members of a syndicate resident in countries that have treaties with the UK that provide for such relief. The SLS applies only where the borrower and the lenders are unconnected and the transaction is on arm's length terms.
EC consults on cross-border interest
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
The European Commission has published a consultation paper on the taxation of cross-border interest and royalty payments between associated companies. The aim of the consultation is to clarify existing legislation while extending its benefits to a wider range of companies by including other legal forms of companies, reducing the threshold to be considered an associated company, and taking account of indirect shareholdings. Comments are invited and should be emailed to the commission by 31 October.
Change in IHT approach to domicile status
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
HMRC have published detailing changes to the circumstances under which they will consider an individual's domicile and decide whether to make a determination of inheritance tax based on the matter. In future, the Revenue will consider opening an enquiry in which domicile could be an issue, or making a determination of IHT in such cases, only where there is a significant risk of loss of UK tax. HMRC will use a wide range of factors to assess the risk. They will depend on the individual case, but will include, for example, a review of the information available about the individual on the department's databases and whether there is a significant amount of tax at risk. The potential costs involved in pursuing an enquiry will be taken into account as will those of potential litigation should the enquiry not result in agreement between the taxman and the individual. read more
Pro bodies clarify trustee residence
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
New guidance on the trust residence rules has been published jointly by the ICAEW Tax Faculty, the Chartered Institute of Taxation and the Society of Trust and Estate Practitioners. The document covers the practical application of the trust residence rules and clarifies when trusts are to be considered UK resident. It uses examples to illustrate the practical application of the legislation and develop some of the principles included in HMRC’s guidance material dated 1 July 2009.
Factsheets aim to help with compliance
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
HMRC have published Revenue & Customs Brief 36/10, which explains the nature of the factsheets issued to taxpayers during a compliance check. The documents are designed to explain matters including how the Revenue conducts compliance checks, what powers it can use, the safeguards in place, and the penalties involved. The factsheets neither replace the detailed guidance in HMRC’s Compliance Handbook, nor do they explain everything about each subject. They are intended only to give taxpayers the most essential information so they are able to make informed decisions.
Pensions overhaul 'needs more work'
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
The Chartered Institute of Taxation (CIOT) has given cautious approval to coalition ministers’ planned revamp of restricting pensions tax relief, but it has said improvement is necessary before the mooted new rules become established in law. The professional body this week submitted its response to the Treasury paper Restriction of Pensions Tax Relief: a Discussion Document on the Alternative Approach, which was issued in late July to set out an alternative approach to regulations introduced by the previous administration in 2010’s first Finance Act. read more
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