On December 6 2011, the Government published its response to the previous round of consultation on the Patent Box, as well as draft PB legislation. The latest round of consultation on this response and the draft legislation closes on 10 February 2012. You can read my comments on the latest position here.
Although I do not generally advise on CFC issues per se, I do have an interest in the latest reform proposals in so far as they impact on IP. In general, I believe that the current CFC reforms are heading in the right direction and the Government is to be congratulated on the efforts being [...]
Followers of my Blog will recall that on 8 December I suggested that one of the proposed changes to the EPW rules in the R&D legislation was (in my view) defective. I believe that the proposed amendment (which deals with the quantum of any EPW claim between connected parties) effectively undoes the main amendment which [...]
I attended a presentation on the latest Patent Box proposals at The Treasury earlier this week. It was a very well organised meeting and extremely useful. It has not, however, changed my concern that the UK’s Patent Box regime is likely to fail to meet the Government's policy objectives. Those objectives, taken straight from one [...]
Readers may recall that I wrote a Blog on 6 September calling for changes in the Externally Provided Worker (EPW) rules. In fact, I have been calling for changes in these rules for some time (see the article published in Tax Adviser). I won't rehearse the arguments in full in this post, suffice it to [...]
Well, what a busy Statement and probably slightly more on the tax front than we were expecting! On the capital allowances front, the Chancellor confirmed that 100% allowances would be made available for investment in Plant & Machinery in 6 enterprise zones; the Black Country, Humber, Liverpool, North Eastern, Sheffield and Tees Valley. Unlike the EZAs [...]
Following on from my post on 21/11/11 with my initial thoughts on Graham Aaronson’s report on a possible GAAR, I wanted to take a look the report from a slightly different perspective. What are the ‘hidden messages’ in that report? Of course, I have to acknowledge upfront that I might have completely misread the report [...]
The Treasury published this morning a report from Graham Aaronson QC on the subject of a General Anti-Avoidance Rule. Aaronson was asked by the Government in November 2010 to look into this. His report, which the Government took 10 days to make public, sets out the views of Aaronson and his team on this question. [...]
At the end of last week, HMRC announced the launch of its R&D Advance Assurance Pilot (as blogged on here on 26 September). Did you spot the announcement? Unfortunately, it was rather hidden away and wasn't even referenced on its "What's New" page. The Pilot relies upon HMRC being able to get sufficient numbers of [...]
As I Blogged on 2nd September, HMRC have been consulting on draft guidance on the meaning of "production" for R&D purposes. This guidance, once finalised, will replace the guidance currently contained in CIRD81350. This latest draft guidance represents quite a step from what had been a very entrenched position for HMRC; it is just a [...]