Finance Bill 2016 was published on 24 March, containing 179 clauses, 25 schedules and running to 571 pages. The Bill is formally titled ‘Finance (No 2) Bill’ of the current Parliamentary session. Explanatory notes have also been made available in two volumes.
Finance Bill 2016 was published on 24 March, containing 179 clauses, 25 schedules and running to 571 pages. The Bill is formally titled ‘Finance (No 2) Bill’ of the current Parliamentary session. Explanatory notes have also been made available in two volumes. Following the Budget, notable additions and changes since the draft clauses were published in December include:
revisions to CGT entrepreneurs’ relief, including, in particular, extending its scope through the introduction of a new ‘investors’ relief’ and reversing several, widely criticised, changes introduced by FA 2015;
amendments to the UK's transfer pricing regime to incorporate the revisions agreed to the OECD transfer pricing guidelines as part of the BEPS project;
extending the new anti-hybrid mismatch rules to neutralise the tax effect of hybrid mismatch arrangements involving permanent establishments;
an overhaul of the royalty withholding tax rules with the imposition of new anti-avoidance measures with effect from 17 March 2016, requiring the deduction of income tax at source in circumstances where arrangements have a main purpose of securing a benefit contrary to the purpose of a double tax treaty;
reform of SDLT rates for non-residential and mixed use properties, with effect from 17 March 2016, to a progressive slice system similar to rules as they apply to residential property; and
clarifications on the scope of the requirement for large businesses to publish a tax strategy and the related new special measures regime.
However, the Association of Taxation Technicians (ATT) has expressed disappointment at the complexity of the qualifying conditions for the new investors’ relief contained in Schedule 14 to the Bill. Michael Steed, ATT president, said he had hoped to see ‘a truly simple scheme that provided a 10% CGT rate where the investment was of a modest nature’. But, he explained, ‘far from providing an additional route to entrepreneurs’ relief’, the new relief, ‘is structured as a free-standing relief with 17 pages of its own qualifying conditions’ which ‘only comes into its own in relation to relatively large investments’.
Finance Bill 2016 was published on 24 March, containing 179 clauses, 25 schedules and running to 571 pages. The Bill is formally titled ‘Finance (No 2) Bill’ of the current Parliamentary session. Explanatory notes have also been made available in two volumes.
Finance Bill 2016 was published on 24 March, containing 179 clauses, 25 schedules and running to 571 pages. The Bill is formally titled ‘Finance (No 2) Bill’ of the current Parliamentary session. Explanatory notes have also been made available in two volumes. Following the Budget, notable additions and changes since the draft clauses were published in December include:
revisions to CGT entrepreneurs’ relief, including, in particular, extending its scope through the introduction of a new ‘investors’ relief’ and reversing several, widely criticised, changes introduced by FA 2015;
amendments to the UK's transfer pricing regime to incorporate the revisions agreed to the OECD transfer pricing guidelines as part of the BEPS project;
extending the new anti-hybrid mismatch rules to neutralise the tax effect of hybrid mismatch arrangements involving permanent establishments;
an overhaul of the royalty withholding tax rules with the imposition of new anti-avoidance measures with effect from 17 March 2016, requiring the deduction of income tax at source in circumstances where arrangements have a main purpose of securing a benefit contrary to the purpose of a double tax treaty;
reform of SDLT rates for non-residential and mixed use properties, with effect from 17 March 2016, to a progressive slice system similar to rules as they apply to residential property; and
clarifications on the scope of the requirement for large businesses to publish a tax strategy and the related new special measures regime.
However, the Association of Taxation Technicians (ATT) has expressed disappointment at the complexity of the qualifying conditions for the new investors’ relief contained in Schedule 14 to the Bill. Michael Steed, ATT president, said he had hoped to see ‘a truly simple scheme that provided a 10% CGT rate where the investment was of a modest nature’. But, he explained, ‘far from providing an additional route to entrepreneurs’ relief’, the new relief, ‘is structured as a free-standing relief with 17 pages of its own qualifying conditions’ which ‘only comes into its own in relation to relatively large investments’.
