Large Corporate

Technical
1 April 2018

Following an announcement at the Autumn Budget, the government published a consultation document on Royalties Withholding Tax on 1 December 2017. Following a meeting with HMRC and HMT, the CIOT responded to these proposals, reiterating our view that, following the US tax reforms, which occurred after the announcement, the proposed measures would not raise any significant revenue for the Exchequer, but would result in significant costs for HMRC (as well as taxpayers) in terms of compliance.

Technical
1 April 2018

The CIOT and ATT have responded to the consultation that followed the government’s announcement at the Autumn Budget 2017 that most non-resident investors in UK land will be brought into UK tax on gains from April 2019.

Technical
1 March 2018

The CIOT has engaged with the government in the ongoing debate about taxation of the digital economy following the publication of a position paper on the digital economy and an autumn Budget proposal for a new royalty withholding tax.

Technical
1 February 2018

The CIOT has responded to HMRC’s recent consultation document which considered how their Business Risk Review (BRR) approach can be improved so it can continue to support a shift in large business tax compliance behaviours and provide greater clarity and confidence for large businesses.

Technical
1 January 2018

The CIOT and ATT have met with the Office of Tax Simplification (OTS) to discuss the potential impact of replacing capital allowances with a deduction for accounting depreciation

Technical
1 November 2017

The Office of Tax Simplification (OTS) has published a call for evidence regarding whether using accounts depreciation to provide relief for capital expenditure instead of capital allowances would simplify the preparation of corporation tax and income tax computations

Technical

The CIOT commented on the draft legislation published in July 2017 in relation to non-doms and substantial shareholding exemption (SSE); these provisions are now incorporated into Finance (No 2) Bill 2017 published on 8 September 2017. In addition, the draft legislation published in July reflected a change that the CIOT had recommended in relation to hybrid mismatch arrangements. The Finance (No 2) Bill 2017 also reflects a change to SSE rules which addresses the concern we raised.

Technical
1 September 2017

The CIOT would welcome your comments on HMT’s consultation on ‘patient capital’ which is defined as ‘long-term investment in innovative firms led by ambitious entrepreneurs who want to build large-scale businesses’. This includes consideration of many tax reliefs which play a role in promoting entrepreneurship including EIS, SEIS, VCTs, Entrepreneurs’ Relief and Business Property Relief.

Technial
1 July 2017

In March 2017 the government published a consultation document which considers proposals to bring non-resident companies within the charge to corporation tax in respect of income arising from UK real property and also gains which are currently taxed as non-resident CGT gains (NRCGT gains). The CIOT commented that we would prefer to see a strategic review of property taxation and that further work should be done on the Exchequer and economic impact of the proposals before any decision is taken.

Technical
1 May 2017

The government is consulting on proposals to move certain non-resident companies from the income tax regime into the corporation tax regime.