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Archive for September 2011

The Tax Gap

There is a famous saying about lies and statistics which is often quoted when anyone doesn’t want to believe the statistics they are being presented with. Indeed, it is true that how you present statistics is as important as the statistics themselves. A recent science experiment on the television presented participants with two plates of…

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Manufactured Overseas Dividends

The Government has taken immediate steps to clarify the tax treatment of Manufactured Overseas Dividends (MOD) by publishing draft legislation to be incorporated within the 2012 Finance Bill. The legislation will take effect for MOD paid on or after the date of the announcement, 15 September 2011, and is estimated to increase tax receipts by…

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UK double taxation treaties and Delaware LLCs

The upper tax tribunal has released its decision in respect of HMRC v George Anson, a case which involved the interpretation of the UK/US double taxation agreement in respect of Delaware LLCs. By way of background it is helpful to understand the following: • A transparent entity is one in which the member is entitled…

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Defined Benefit Schemes

Defined Benefit schemes have taken a hefty knock in recent years. These schemes, otherwise known as Final Salary Schemes, promise an employee a set percentage of their salary on retirement. Usually calculated in 60ths or 80ths the percentage is often based on the number of years in which the employee worked for the company. Once…

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The future for property

Anyone reading the financial papers over the past few weeks will be thoroughly confused by what is actually happening to property. For a start, are prices rising or falling? The Centre for Economics and Business Research says that by 2015 prices will have risen by 14% to a new all time high. Contrast this with…

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Tax Treaties Anti-Avoidance legislation

N.B. On 9 September 2011 the Government announced that in view of concerns raised it has “decided not to proceed further with the consultation on the proposed legislation and will not include it in Finance Bill 2012.” The recent announcement of the agreement between Swiss and UK authorities in respect of taxation on investments held…

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