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US Government Introduce a Five-Million-Dollar Incentive to Move Offshore

One of the reasons that you won’t often find me commenting on US tax issues is that the US government have a lot of very nasty laws that they are prepared to use on anyone they think might be encouraging their citizens to evade or even just avoid tax – even though tax avoidance is [...]

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Over 1,000 Tax Reliefs to be Reviewed

On July 20th this year the Chancellor George Osborne announced the establishment of the Office of Tax Simplification (“OTS”) charged with the task of providing the Government with independent advice on simplifying the UK tax system. Not before time! Today the OTS announced details of two initial reviews, which are to be completed before the [...]

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Is Offshore Banking Legal?

Is offshore banking legal? This is a question often asked these days, as various nations seek to clamp down on offshore tax havens and offshore banking. And while such banking may raise eyebrows in certain quarters, or invite disapproving comments from politicians seeking to balance budgets and maximise tax revenue, the fact is banking offshore [...]

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Capital Gains Tax Update

Capital Gains Tax (“CGT”) was introduced by Harold Wilson’s Labour Government in 1965. Its purpose was simple: To tax the profit or “gain” made on the sale or “disposal” of an asset by individuals. Companies do not pay CGT but instead any gain is taxable as part of their Corporation Tax bill. The original reason [...]

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What is the Enterprise Investment Scheme?

The Enterprise Investment Scheme offers generous income tax and capital gains tax reliefs to investors in certain companies. These reliefs are available to “qualifying individuals” who subscribe for “eligible shares” in “qualifying companies” undertaking “a qualifying business activity”. Simple, isn’t it? The purpose behind the scheme is to encourage investment in start up companies and [...]

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Time for the Headline Rate of Corporation Tax To Be Cut

Now that George Osborne has finally made it to 11 Downing Street and is planning his “Emergency Budget”, I hope he look seriously at reducing the headline rate of Corporation Tax in order to attract international businesses to the UK as well as stemming the flow of UK companies moving their tax residence elsewhere. The [...]

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You Can Reclaim Inheritance Tax

I was talking to an Independent Financial Advisor a couple of days ago and in conversation asked him how he was getting on winding up the estate of a mutual client who died about 18 months ago. “Fine”, he said, “but it looks like we have paid too much Inheritance Tax on the house” – [...]

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What Will Vince Cable Do Now For The Isle of Man?

Just over a year ago I wrote about the visit to the Isle of Man undertaken by Vince Cable, then Liberal Democrat Shadow Chancellor who today was appointed Secretary of State for Business and Banking in the new Conservative – Liberal cabinet. Despite having been a stern critic of the island, calling it a tax [...]

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Tax Exemption for Start Up Companies in Ireland

To try and deal with some of the economic problems encountered last year when Ireland’s “Celtic Tiger” economy collapsed in chaos, the Irish Government introduced a tax holiday for companies which commenced trading during 2009 under which, subject to certain conditions, they would pay no tax for a three year period. As things have not [...]

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Five Ways to Save Inheritance Tax

Benjamin Franklin said, “In this life nothing is certain but death and taxes”. When anyone who is resident or domiciled in the UK dies those they leave behind will find that HMRC will want a slice of the dead person’s estate – their money, house, possession etc. This tax used to be called Death Duties [...]

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How to Maximise Your Capital Allowances

Any business can claim tax allowances, called capital allowances, on certain purchases or investments. This results in a reduction in the business tax bill – which can’t be bad. In general capital allowances are available on plant and machinery, buildings – including converting space above commercial premises to flats for renting – and research and [...]

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How Much Can I Put In An ISA?

I’ve suddenly had a lot of people contact me to ask the above question regarding the tax free ISA (Individual Savings Account) products that are available to UK taxpayers. This is probably due to changes that came in last month. If you don’t know what an ISA is then have a look at this earlier article. [...]

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What Is Transfer Pricing?

“Transfer pricing” is an increasingly important and contentious area of international tax law. This is because so much of modern world trade involves the transfer of goods, intangibles or services within multinational enterprises (MNEs) – groups of companies or related businesses based in 2 or more countries. Such international trade offers scope for an MNE [...]

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Political Double Dealing

On his 2008 Presidential campaign trail, Barack Obama made his hostility toward “offshore” jurisdictions very clear: “There’s a building in the Cayman Islands that houses supposedly 12,000 U.S.-based corporations. That’s either the biggest building in the world or the biggest tax scam in the world, and we know which one it is.” I know that [...]

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Taxman Faces Writs for VAT Errors

HM Revenue & Customs are facing a flood of legal claims that will blow another massive hole in the public finances. In the past few weeks thousands of High Court claims have been lodges by companies and local councils relating to millions of pounds of interest wrongly charged by HMRC. When HMRC makes a repayment [...]

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UK Budget Bombshell for Second Home Owners

A shock announcement in the small print of this year’s budget has left thousands of UK farmers and second home owners reeling at the loss of tax breaks without which they may have to sell up. Not a good thing in a falling market. But it could benefit owners of foreign holiday property. Buried deep [...]

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Offshore Tax Havens: Who Did Chancellor Merkel Have in Mind?

Anyone setting up a business in Germany has a few problems to overcome. High taxation, high social charges, and high cost of company formation to name just three. That’s why more and more Germans are setting up companies in the United Kingdom. Believe it or not, the UK remains very business friendly. Anyone can set [...]

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Withholding Tax Under Challenge

I recently received a question from the owner of a UK company questioning the imposition of Spanish withholding tax on payments his company received from a Spanish subsidiary. He thought that the EU Parent-Subsidiary Directive exempted the tax. In fact it would do for dividends but not for royalty payments, which these payments were for [...]

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UK Government to Review Offshore Financial Centres

The British Treasury has set up an independent review to examine the operations of offshore financial centres and their effect on the UK economy. The review will look at the current and future risks posed by the current economic crisis to the financial business of British Crown Dependencies and Overseas Territories including Jersey, Guernsey, the [...]

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Good News! – Yet Another U-Turn from the Labour Government

In his Pre-Budget Statement on Monday Alistair Darling quietly dumped legislation intended to outlaw income splitting arrangements among individuals that would have effectively forced small, family-run businesses to pay more tax. For some years now the Labour government has tried to take action against income splitting arrangements which it considers “unacceptable tax avoidance”. Leaving aside [...]

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