OMB

Technical
1 November 2017

HMRC have recently issued a consultation document ‘Large Business compliance – enhancing our risk assessment approach’.

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

HMRC have published their long awaited guidance on the distributions on company winding up (or phoenixing) Targeted Anti-Avoidance Rule (TAAR) introduced by Finance Act 2016.

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.

Technical
1 September 2017

The Office of Tax Simplification (OTS) has published a focus paper calling for views on whether disincorporation relief (which is due to expire on 31 March 2018) is achieving its purpose.

Technical

Following consultation, the draft provisions introducing the cash basis for the calculation of the taxable profits of property businesses were included in Finance (No. 2) Bill 2017 at Clause 19 and Schedule 5. These provisions were dropped from the pre-election Finance Act 2017. At the time of writing we do not know whether (and from what date) the provisions may be re-introduced. However, as the proposed statutory cash basis for property businesses owes its origin, at least in part, to Making Tax Digital, it is reasonable to assume that it will be re-introduced. Therefore we continue to raise issues with HMRC based on the draft provisions.

Technical
1 June 2017

The CIOT has responded to one aspect of the Housing White Paper that considers land pooling as an effective contribution to assembling land for sustainable development

Technical

The CIOT and LITRG have commented on the draft primary legislation published on 31 January 2017.

Technical
1 March 2017

The CIOT welcomes the fact that HMRC have chosen to consult on the future of the advance assurance service prior to making significant changes to the service, but we are concerned that the consultation is not addressing the root causes of why demand for the service is increasing so much.

Technical

Responses by LITRG and ATT on the new trading and property allowances available from 6 April 2017 highlight the need for clear guidance, the difference in treatment of trading income for tax and universal credit purposes and several detailed practical issues.