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Other news in brief

Tax news in brief 14 Sep 2018

A round up of other news this week.


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The OECD has released new guidance on Country-by-Country (CbC) reporting. The additional guidance, for both taxpayers and tax administrations, aims to provide further clarity on a number of specific points relating to preparation of CbC reports, including treatment of dividends and employee numbers where proportional consolidation is used when preparing the financial statements. The updated guidance also clarifies that shortened amounts should not be used in completing Table 1 of a CbC report and contains a table that summarises existing guidance on the approach for mergers, demergers and acquisitions.

The Tonnage Tax training requirement has been amended with effect from 1 October 2018 by The Tonnage Tax (Training Requirement) (Amendment etc.) Regulations 2018. The change made is to increase payments in lieu of training (PILOTs) in line with UK inflation. A company which is unable to provide the required training may propose to make PILOTs. The new Regulations increase the PILOT from £1,259 to £1,284 per calendar month per trainee with effect from 1 October 2018. There are penalties for non-compliance in the form of a 50 percent or - for repeated non-compliance – 100 percent increase in the basic rate of PILOTs payable in following periods. The Regulations also increase the basic rate from £1,172 to £1,195 per calendar month per trainee with effect from 1 October 2018.

HMRC high level guidance entitled Use the Enterprise Investment Scheme (EIS) to raise money for your company has been updated to include the new ‘risk to capital’ conditions which must be met in for an investment to qualify for EIS.

HMRC have published Corporation Tax receipts figures for the financial year ending 31 March 2018 showing an increase of 11 percent on the previous year. The underlying figures show that CT liabilities for the Finance and Insurance sector increased by 60 percent and the total number of companies with a CT liability was almost 1.5 million, up 9 percent from the previous year.

The First-tier Tribunal (FTT) published two decisions relating to appeals against discovery assessments made by HMRC relating to Stamp Duty Land Tax (SDLT), rejecting the taxpayers’ appeals in both cases. In the Astar decision, involving a business incorporated in the Bahamas without a place of business in the UK, the FTT found that an SDLT discovery notice sent to the address of the purchased property, rather than the company’s principal place of business is deemed to be validly served on the taxpayer. In the Miller & Anor decision, the FTT rejected the taxpayer’s request to make a late appeal against SDLT discovery assessments due to being unaware of any enquiry or assessments and the lack of experience of their advisors.

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