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FA 2015


The government announced a new exemption for withholding tax on private placements – a potentially important source of non-bank funding for UK businesses – at the Autumn Statement. James Hume (Slaughter and May) reports.

HM Treasury has suggested that the government may narrow the notification requirements of, and widen the exclusion for loan relationships for, the proposed diverted profits tax (DPT).

As announced in the Autumn Statement, the government has published draft regulations (The Companies Act 2006 (Amendment of Part 17) Regulations, SI 2015/Draft) to prevent companies avoiding stamp taxes by carrying out takeovers using cancellation schemes of arrangement.

Peter Cussons examines the potential EU law and international issues facing the UK's diverted profits tax.

Laura Charkin and Stephen Pevsner (King & Wood Mallesons) review the rules in the draft Finance Bill 2015

Pete Miller (The Miller Partnership) analyses the changes to entrepreneurs’ relief and goodwill amortisation in draft FB 2015

The government’s new diverted profits tax (DPT), which was initially announced in December’s Autumn Statement and comes into effect on 1 April 2015, was debated in the House of Commons on 7 January 2015.

Commentary prepared by the Tolley tax team on the draft Finance Bill 2015 rules on:

  • special purpose share schemes, with comment from Ashley Greenbank (Macfarlanes);
  • diverted profits tax, with comment from Sandy Bhogal (Mayer Brown);
  • investment managers and disguised fee income, with comment from Ben Eaton (Goodwin Procter);
  • bank loss relief, with comment from Anna Anthony (EY).

Tolley commentary on the draft tax legislation for Finance Bill 2015

It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.

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