BEPS Pillar Two: Charging mechanisms

This session focusses on special issues related to non-UK-resident directors/non-executive directors and UK LLP members working outside the UK as well as going through illustrative examples.

Overview of the key concepts and issues to be aware of for both non-UK employers and UK employers with mobile employees coming to the UK to work and for employees working abroad. The session covers Pay As You Earn (PAYE), National Insurance Contributions (NICs) and immigration issues as well as going through illustrative examples.

An overview of the building blocks of stamp duty reserve tax covering agreements assessable to SDRT, chargeable securities, the interaction between stamp duty and SDRT, timings and penalties in respect of both stamp duty and SDRT, and exemptions and reliefs.

An overview of the building blocks of stamp duty covering what constitutes a "transfer on sale", assets chargeable to stamp duty, questions surrounding consideration, and exemptions and reliefs.

Overview of anti-hybrids legislation, covering key definitions (including Finance Act 2021 changes to "acting together"), Chapter 3 (hybrids financial instruments), Chapter 5 (hybrid payer D/NI mismatches), Chapter 7 (hybrid payee D/NI mismatches), Chapter 9 (hybrid entity DD mismatches), Chapter 11 (imported mismatches) and the TAAR.