Accession Tax The Liberal Democrats have been in the news again recently proposing alternatives to the current Inheritance Tax regime. One of their favourites is the implementation of an Accession Tax (See Liberal Democrats Policy Consultation Paper 107). Of all the OECD countries, Ireland is the only country we are aware of which has implemented an Accession…
DetailsThe Isle of Man Disclosure Facility – IoMDF – Manx Discloure Facility – MDF On 19 February HM Treasury announced a tax co-operation agreement with the Isle of Man. The Memorandum of Understanding agreed between the two governments provides for: the automatic exchange of information (eg details of bank accounts) to combat tax evasion. a…
Details19th February 2013 HM Treasury has announced a new Isle of Man Disclosure Facility – IoMDF. Below we have reproduced the Press Release but we will be bringing you our detailed analysis of the new facility shortly along with considerations as to whether the IoMDF is a game changer in terms of either the UK/Swiss Agreement or…
Details13 February 2013 On the 5th December 2012, the Chancellor delivered his Autumn Statement. A week later the draft clauses for the Finance Bill 2013 were published. Notable by its absence was the draft legislation for the extension of CGT to non resident non natural persons (the “extension to CGT”), which had been heavily anticipated.…
Details14th December 2012 Taxation of High Value Residential Property The Budget on 22 March 2012 included 3 announcements relating to UK residential properties worth more than £2m. 1. Increased SDLT rates with immediate effect. 2. A proposal for an “Annual Charge” on “high value” properties held by “non-natural persons”, now referred to as the Annual Residential…
DetailsBackground to the Judgment (issued Nov 2012) This Judgment is but the latest iteration in a long running case. The group litigation was brought before the UK courts in 2003. The crux of the matter is that the claimants believed the then UK taxation of cross border dividends was contrary to Art 49 Freedom of Establishment) and Art…
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