The following measures, announced at last week’s Autumn Statement, take place with immediate effect:
Corporation tax – preventing abuse of late paid interest rules: The government will repeal rules concerning the timing of relief for loans made to UK companies by connected companies in ‘non-qualifying’ overseas territories. This will have effect for new loans entered into on or after 3 December 2014. For existing loans, the repeals will have effect from 1 January 2016. This repeal forms part of the review of legislation on corporate debt, for which related anti-avoidance legislation will be published separately for comment on 10 December 2014;
Corporation tax – bank loss relief restriction: Legislation in FB 2015 will restrict to 50% the proportion of annual taxable profit that banks can offset by certain carried-forward reliefs from 1 April 2015. The restriction will apply to carried forward trading losses, non-trading loan relationship deficits, and management expenses accruing up to 1 April 2015. Two targeted anti-avoidance rules which form part of the measure will apply to arrangements entered into on or after 3 December 2014;
Corporation tax – restricting relief for internally generated goodwill transfers: Draft legislation has been published to restrict the corporation tax relief a company may obtain for the goodwill associated with a business it acquires from a related individual or partnership, affecting acquisitions on or after 3 December 2014.
Denying CGT entrepreneurs’ relief for disposals of goodwill to related companies: Draft legislation has been published to prevent individuals from claiming entrepreneurs’ relief on disposals of the goodwill associated with a business they transfer to a related close company, affecting transfers on or after 3 December 2014.
Income tax miscellaneous loss relief: Legislation in FB 2015 will deny miscellaneous loss relief for income tax purposes where a miscellaneous loss, or miscellaneous income, arises from relevant tax avoidance arrangements, with effect from 3 December 2014. The legislation will also limit the loss relief to ‘relevant miscellaneous income’ chargeable to tax under the same provision as the loss would have been chargeable had it been profits, with effect from April 2015.
The following measures, announced at last week’s Autumn Statement, take place with immediate effect:
Corporation tax – preventing abuse of late paid interest rules: The government will repeal rules concerning the timing of relief for loans made to UK companies by connected companies in ‘non-qualifying’ overseas territories. This will have effect for new loans entered into on or after 3 December 2014. For existing loans, the repeals will have effect from 1 January 2016. This repeal forms part of the review of legislation on corporate debt, for which related anti-avoidance legislation will be published separately for comment on 10 December 2014;
Corporation tax – bank loss relief restriction: Legislation in FB 2015 will restrict to 50% the proportion of annual taxable profit that banks can offset by certain carried-forward reliefs from 1 April 2015. The restriction will apply to carried forward trading losses, non-trading loan relationship deficits, and management expenses accruing up to 1 April 2015. Two targeted anti-avoidance rules which form part of the measure will apply to arrangements entered into on or after 3 December 2014;
Corporation tax – restricting relief for internally generated goodwill transfers: Draft legislation has been published to restrict the corporation tax relief a company may obtain for the goodwill associated with a business it acquires from a related individual or partnership, affecting acquisitions on or after 3 December 2014.
Denying CGT entrepreneurs’ relief for disposals of goodwill to related companies: Draft legislation has been published to prevent individuals from claiming entrepreneurs’ relief on disposals of the goodwill associated with a business they transfer to a related close company, affecting transfers on or after 3 December 2014.
Income tax miscellaneous loss relief: Legislation in FB 2015 will deny miscellaneous loss relief for income tax purposes where a miscellaneous loss, or miscellaneous income, arises from relevant tax avoidance arrangements, with effect from 3 December 2014. The legislation will also limit the loss relief to ‘relevant miscellaneous income’ chargeable to tax under the same provision as the loss would have been chargeable had it been profits, with effect from April 2015.
