13 Sep 2016

EITI and The Reports on Payments to Governments Regulations 2014; a sense of déjà vu.

Summary Qualifying Companies are under an obligation to disclose information under The Reports on Payments to Governments Regulations (“the Regs”).  Certain selected companies have also received the EITI questionnaire templates. Whilst the EITI regime is “voluntary” the EU sponsored regime under the Regs is compulsory and requires certain companies to make a return in a prescribed form with Companies House. The first payments covered are those made in 2015 and for a company with a December year end the deadline […]


07 Sep 2016

Finance Bill finishes third reading in the House of Commons

The Finance Bill 2016 completed its third reading in the House of Commons yesterday (6th), and has now been passed on to the House of Lords. As it is a money bill, its terms cannot be amended by the House of Lords so the committee stage, report stage and third reading there are just formalities.  The first reading in the Lords also took place yesterday and the second reading and remaining stages are scheduled for 13th September, after which the […]


24 Aug 2016

Changes to Derivative Contract Rules

Changes to derivative contract rules – reminder of time limit for non-large companies. Deadline fast approaching for small and medium sized companies to make election Some companies may not be grandfathered even though fair valuing has been the policy Election should be made if there is any doubt otherwise companies will be taxed on fair value movements Detail Readers will recall from our newsletter of April 2015 that there are strict time limits to make the election to operate the […]


22 Jul 2016

Loss streaming: Back where we started?

The Upper Tier Tribunal have overturned last year’s First Tier Tribunal decision in the Leekes V HMRC  case, and held that losses are required to be streamed even where the whole of the predecessor’s trade is transferred. In our Newsbrief of 16 March 2015  we reported that the First Tier Tribunal decision meant that where a company succeeded to a trade carried on by a group company there was no requirement to stream. This confirmed our view of the law […]


19 Jul 2016

Enactment of Finance Bill 2016-17 expected early September

The progress of the Finance Bill 2016 was interrupted by the EU referendum. The Committee stage was completed on the 28th June, but this left insufficient time to progress to the report stage/third reading, and Royal Assent, before Parliament rises for the summer recess on 21st July. Our newsletter of 25th May explains. Completion of the House of Commons report stage and third reading of the Finance Bill is the point at which changes can be accepted as substantively enacted […]


22 Jun 2016

Potential Adjustments to Transfer Pricing Legislation

The government is looking at the possible introduction of a secondary adjustment rule into the UK’s domestic transfer pricing legislation. The consultation document was published on 26 May 2016 seeking views on whether such a feature should be introduced and if so its design. Background Under the transfer pricing rules taxable profits are calculated based on an arm’s length price. The UK has adopted the arm’s length principle based on the OECD Model Tax Convention. Where the price is not […]


14 Jun 2016

Diverted Profits Tax – deadline approaches

The extended notification period for Diverted Profits Tax (DPT) for the first affected accounting periods (those ending on or before 31 March 2016) permits notification up to 6 months after the end of the period instead of the normal 3 month deadline. For further background, see below. Diverted Profits Tax key points: Notification deadline is looming Assessing whether to notify is not straightforward Not notifying may lead to greater uncertainty, and potentially penalties For oil and gas sector companies we […]


09 Jun 2016

Deferral of PRT returns

Introduction Companies need to think about preparing the PRT returns for CP I 2016, the first period for which the zero % rate is to apply. Ongoing discussions between industry and HMRC may shape the form of future returns or indeed the extent to which companies feel it necessary to make returns. Now is a good time to revisit the options available to companies. If you wish to discuss your companies’  PRT returns with one of our team please get in touch.  Discussion […]


31 May 2016

Reform to loss relief, and changes to SSE and DTTP – new consultations published

Proposed changes to the use of carried forward losses and potential amendments to the existing Substantial Shareholding Exemption regime were announced at Budget 2016. Consultation documents are now available for comment. In addition, a new consultation on a possible simplification of the Double Taxation Treaty Passport (DTTP) scheme was announced on 26 May 2016. Reform to corporation tax loss relief: New rules apply from 1 April 2017 Use of losses carried forward restricted to 50% of profits £5m group-level allowance Losses […]


27 May 2016

Restriction on interest deduction – Will the Ring Fence be affected?

From 1 April 2017 new rules will restrict interest deductions for the larger UK groups. Although HMRC has agreed that ring fence interest deductions are not to be impacted by these rules, the level of ring fence deduction within a group may impact the level of restriction for non ring fence deductions. There is still time to make representations on how the new rules will operate. The second consultation document was published on 12 May It seeks views on the […]