Tax analysis: HMRC has launched a consultation on the draft legislation for the Residential Property Developer Tax (RPDT) ahead of its inclusion in the 2021–22 Finance Bill. This follows the government holding a consultation seeking views on the policy design of the new RPDT between 29 April and 22 July 2021. Ian Zeider, knowledge counsel at Travers Smith and Cathryn Vanderspar discuss the draft legislation and possible issues.
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British Tax Review Issue 4, 2021 – Finance Act 2021, Sections 121–124 and Schedules 30–32: avoidance
Tax Partner Simon Skinner and Senior Associate Hugh Brooks have written an article for the latest British Tax Review on recent changes of law relating to HM Revenue and Customs powers in relation to disclosures of tax avoidance schemes, and promoters and enablers of such schemes (British Tax Review Issue 4, 2021). A PDF of this contribution is linked below. Alternatively you can download to print, to save for later or for a different experience.
Travers Smith has sponsored the inaugural Private Equity International Women in Private Funds report.
Tax partner Elena Rowlands, Head of Real Estate Tax Cathryn Vanderspar and Knowledge Counsel Ian Zeider have written the lead article in a recent edition of Tax Journal in which they set out their views on the government's proposals for a new tax privileged asset holding company regime. You can read the full article below.
Mahesh Varia has contributed the United Kingdom Chapter to the ninth edition of The Executive Remuneration Review.
In this article Natalie Scoones, George Weavil and Jessica Kemp discuss why a debt for equity swap is likely to play a role in many restructurings that result from the downturn triggered by the COVID-19 pandemic. They explain how such transactions are structured, the likely motivations of key stakeholders and the tax and regulatory implications of such transactions.
New legislation in Finance Act 2020 legislates retrospectively for HMRC to use artificial intelligence to carry out its functions. The article below was written for Tax Journal's September issue by Hannah Manning, Sophie Lloyd and Laura Jackson, and considers in particular some areas of potential concern in relation to HMRC's increasing use of automation, such as the raising of discovery assessments, business risk reviews and the assessment of discretionary penalties.
Partner and Head of Tax, Emily Clark, discusses why gathering and reporting investor tax information is becoming an increasingly important issue for private equity funds.
Mahesh Varia has contributed the United Kingdom Chapter to the eighth edition of The Executive Remuneration Review.
It has been settled HMRC practice for some time now that the 1.5% stamp charge set out in FA 1986 in relation to the issue and transfer of UK shares to clearance services and depositaries was restricted by EU law, such that it should arise only on the transfer of shares which were not integral to the raising of capital for the company in question.