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ESG x Tax in the UK Spring Budget 2023

As noted in our overview of Budget measures here, there were a number of tax announcements dealing with environmental issues as the government seeks to meet its commitment to net zero.

Advantages of Jersey / Guernsey companies as UK ‘qualifying asset holding companies’ (QAHCs)

A crucial requirement for QAHC eligibility is that the company is UK tax-resident, but not that it is a UK company.

UK Budget delivers measured optimism

The life sciences sector also did better than some might have anticipated.

UK defers aggregates levy changes

The generalised incidental extraction exemption, which was originally proposed by Pinsent Masons in response to a government consultation, will be welcomed by businesses in the infrastructure industry.

Spring Budget 2023: calm after autumn storms

Once over the lifetime allowance, the excess is subject to a tax charge at 55 per cent on receipt of a lump sum and 25 per cent otherwise.

CJEU: EU law no barrier to UK tax charge on intra-group transfers

All parties were agreed that the UK group transfer rules – within the intangible fixed assets regime and capital gains regime respectively

NewsCorp Supreme Court VAT ruling has wide implications

NewsCorp argued that the underlying purpose behind the VAT zero-rating of physical newspapers carries through to digital versions of publications such as The Times and The Sun, for e-readers, tablets, phones and websites.

Singapore to implement 15% minimum effective tax rate in 2025

BEPS refers to tax planning strategies that take advantage of tax loopholes and mismatches to shift profits indirectly to low-tax areas where there is little or no economic activity, or to erode the tax base via allowable deductions such as interest or ro

HMRC issues in-depth guide to alternative tax dispute resolution

The decision rests with the mediator, so any taxpayer who specifically wishes to conduct an ADR meeting in person will need to make representations to the mediator early in the process.

The British Virgin Islands and the EU List of Non-Cooperative Tax Jurisdictions

The BVI has requested a supplementary review to more accurately reflect the current legislative status with a view to having the BVI removed from the list as soon as possible.

Notification of uncertain UK tax treatment by large businesses

This was not included in the final legislation in the 2022 Finance Act, although HMRC said that the government is committed to further consideration of this third trigger and could add it to the legislation later.

UK: HMRC changes to notification process for opting to tax on land and buildings

Tenants and buyers will usually also ask to see evidence of the landowner's OTT, if they are going to be expected to pay VAT on their consideration given for the lease or purchase of the property.

UK tax treatment of REITs

Qualifying property companies can elect for REIT status.

Report on use of financial institution notices (FIN) published

They are one of HMRC’s tools for obtaining information about a person’s tax affairs.

Tax and the British Virgin Islands: Separating Myth From Reality

The reality is that the British Virgin Islands has a robust anti-money-laundering and anti- terrorist-financing regime through the enactment of the Proceeds of Criminal Conduct Act 1997

The UK's diverted profits tax regime

The rate differential between DPT and corporation tax means that affected companies will often seek to restructure their operations to pay more corporation tax, rather than paying DPT.

IR35: taxation of off-payroll workers explained

The new rules have created significant cost and compliance challenges for businesses that rely heavily on a flexible workforce.

Waqar Shah and Tabassum Khan for Taxation Magazine on the CJEU GE Aircraft Engine Services Ltd decision

The ruling was a success for the Mishcon de Reya Tax Disputes team and is significant in setting out the CJEU's position on the VAT implications for the supply of vouchers from a taxable person to its staff.

VAT: changes in processing option to tax forms

From February 2023, HMRC will only issue an automated acknowledgement of receipt of a notification of an option to tax sent by email.

Tax analysis advised in Luxembourg after Budget law passed

The changes affect Luxembourg tax transparent entities operating in Luxembourg with foreign shareholders where those shareholders hold at least 50% of voting rights or capital in the Luxembourg entity or hold entitlements to at least 50% of its profits.