A number of anti-avoidance measures including anti-fragmentation rules and changes to Controlled Foreign Company rules were announced in the Budget 2018 to be enshrined in legislation in the Finance Act 2019.

In the Autumn 2018 Budget, the government introduced a new capital allowance for new non-residential structures and buildings.

Since 2010, HMRC have raised an additional £2.9 billion through its focus on offshore non-compliance, through initiatives including 6 separate disclosure facilities, a deal with Switzerland and the introduction of a series of legislative measures, giving HMRC increased powers to assess older liabilities, charge higher behaviour-related penalties and also to mount criminal prosecutions for the facilitation of tax evasion.

On the 5th March 2019 the Government released its latest Consultation on IR35 in the private sector, which seeks discussion on refinements needed to implement the public sector legislation into the private sector.

Rebecca Walker considers the recent Tribunal case of Petrol Services Ltd which saw HMRC successfully argue that the split contract arrangement did not work; all income was a result of the directors’ office holding, with none attributable to the separate consultancy contracts in place.

EU companies contrasted with the rest of the world and reduced their global R&D share in ICT industries and showed reductions in low tech and Chemicals sectors whilst increasing innovation in Automotive and Aerospace.

Changes announced by the government to the R&D scheme for SMEs will come into force from early 2020 in an attempt to persuade companies to employ technical staff rather than outsourcing their R&D activities to third parties.

HMRC’s stance on the valuation of goodwill in trade-related properties has become much stricter. Therefore advisors need to be prepared for their original valuations to be robustly challenged. Plan for the worst and hope for the best!

Our round-up of topical news this month features clients who make partial surrenders on life insurance products face unfair tax charges unless they take action, following the case of Lobler V HMRC and we compare the legislation regarding who should file a self-assessment tax return with HMRC’s guidance. 

Our round-up of topical news this month features the new €10,000 threshold coming in from 1 January 2019 for micro-businesses selling digital services to EU consumers and how HMRC has recently made changes to the guidance on how some of the conditions of S396B may apply.