In Folder: 2013
Representation by the Tax Faculty of ICAEW responding to draft legislation published by HM Revenue and Customs on 11 December 2012 proposing a cap on unlimited income tax reliefs, submitted on 6 February 2013; highlights concerns about impact on SMEs, restriction of commercial loss relief and loan interest, lack of targeting, need for transitional provisions and postponement to 2014/15, interaction with AIA and pension contributions, treatment of share loss relief for EIS/SEIS, and clarity of adjusted net income; includes an illustrative example and Appendix 1 setting out the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
ICAEW Tax Faculty representation responding to HMRC's consultation on matching rules for the benefits charge under the transfer of assets abroad (TOAA) regime; sets out key concerns about EU law compliance, fairness, and legislative complexity; includes introduction, who we are, key point summary, major points, responses to consultation questions, and the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
10/10/13, 12:00 AM
Representation submitted by the Tax Faculty of ICAEW on 6 February 2013 responding to draft Finance Bill clauses and a Technical Consultation on the deferral of corporate exit charges; sets out concerns regarding compliance with EU law, argues for deferral until realisation, discusses scope across assets including chargeable and intangible assets, loan relationships and derivatives, and addresses questions on reporting thresholds, annual returns, choice between immediate payment, instalments and realisation methods, and the limited use of security; includes the Tax Faculty's Ten Tenets for a Better Tax System as an appendix. (AI generated description)
2/6/13, 12:00 AM
Memorandum submitted on 6 February 2013 by the Tax Faculty of ICAEW in response to an invitation from HM Treasury and HM Revenue and Customs to comment on draft Finance Bill 2013 legislation on employee shareholder status: capital gains tax exemption; sets out the key point that the policy intention is negated by new subsection 236B(3) and recommends rewriting section 236B to clarify scope; includes introduction; who we are; key point summary; general comments; detailed comments on the draft legislation; Ten Tenets for a Better Tax System; comments on various aspects of employee ownership shares. (AI generated description)
2/6/13, 12:00 AM
Memorandum submitted on 6 February 2013 by the Tax Faculty of ICAEW in response to HMRC's 'Ensuring the fair taxation of residential property transactions: summary of responses' (December 2012); comments on annual residential property tax (ARPT), SDLT slab system and reliefs; concerns over targeting, complexity, administration and timetables; points on farming companies, property rental businesses, historic homes, remittances and CGT; includes introduction; who we are; general comments; major points; Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
Memorandum submitted on 6 February 2013 by the Tax Faculty of ICAEW responding to HM Treasury and HM Revenue and Customs' consultation on draft Finance Bill 2013 legislation concerning Enterprise Management Incentives qualification for CGT entrepreneurs' relief; includes introduction, who we are, key point summary, general comments, detailed comments on the draft legislation, and the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
Memorandum submitted in February 2013 by the Tax Faculty of ICAEW to HM Revenue and Customs in response to draft legislation published on 11 December 2012 extending IR35 for income tax to office holders; includes introduction, who we are, major points on scope and application, and the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/1/13, 12:00 AM
Memorandum submitted in February 2013 by the Tax Faculty of ICAEW to HMRC in response to draft legislation on disincorporation relief published on 11 December 2012. Contents include: introduction; who we are; key point summary; comments on the draft legislation; Ten Tenets for a Better Tax System. Key recommendations include increasing the GBP 100,000 asset limit and removing the proposed five-year time limit for the relief. (AI generated description)
2/1/13, 12:00 AM
ICAEW Tax Representation compiling briefings submitted in April, May and June 2013 by the Tax Faculty to the Public Bill Committee on Finance Bill 2013; contents include: Clause 16 and Sch 3 - limit on income tax reliefs; Clause 17 and Sch 4 - cash basis for small businesses; Clause 22 - arrangements made by intermediaries; Clause 26 and Sch 10 - transfer of assets abroad; Clause 30 - loss relief surrenderable by non-UK resident established in EEA state; Clauses 57-60 - disincorporation relief; Clause 64 and Sch 24 - charge on certain high value disposals by companies etc; Clause 76 and Sch 28 - close companies; Clauses 203-212 - general anti-abuse rule; Clause 226 and Sch 47 - corporation tax: deferral of payment of exit charge; Clause 227 and Sch 48 - penalties: late filing, late payment and errors. (AI generated description)
1/1/13, 12:00 AM
Memorandum by the ICAEW Tax Faculty commenting on the draft clauses for inclusion in Finance Bill 2013 published on 11 December 2012; includes general comments on tax policy making, consultation, simplification and HMRC capacity; detailed comments cover the statutory residence test; annual investment allowance; employee shareholder CGT exemption; EMI CGT entrepreneurs' relief; extension of IR35 to officers; attribution of gains to members of closely controlled non-resident companies and transfers of assets abroad; cap on unlimited income tax reliefs; cash basis for small business; fixed rate deductions; deferral of corporate exit charges; UK group relief amendments; taxation of residential property transactions; GAAR; withdrawal of notice to file; RTI penalties; vulnerable beneficiary trusts; disincorporation relief; includes the Tax Faculty's ten tenets for a better tax system. (AI generated description)
2/15/13, 12:00 AM
Representation submitted on 6 February 2013 by the ICAEW Tax Faculty commenting on proposals to introduce a GAAR and HMRC's draft GAAR Guidance; covers targeting and certainty, guidance examples, clearance, international legality, transitional rules and likely future impact; includes the Tax Faculty's Ten Tenets for a Better Tax System. Contents include: Introduction; Who we are; Our comments; Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
Representation submitted on 22 February 2013 by the ICAEW Tax Faculty in response to HMRC draft legislation and explanatory notes on high value residential properties published on 31 January 2013; addresses Annual Residential Property Tax, Capital Gains Tax and Stamp Duty Land Tax; includes key point summary, analysis of reliefs, administration and payment issues; appendices cover anti-fragmentation draft legislation examples, refinancing of borrowing, and the Ten Tenets for a Better Tax System. (AI generated description)
2/22/13, 12:00 AM
Memorandum submitted on 28 August 2013 by the Tax Faculty of ICAEW in response to a consultation document published on 6 June 2013 by HM Revenue and Customs on modernising the taxation of corporate debt and derivative contracts; includes introduction, who we are, key point summary, responses to consultation questions across areas such as timetable and framework, accounting issues and hedging, connected party debt, intra-group transfers and group continuity, anti-avoidance measures and tax impact assessment; includes the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
8/28/13, 12:00 AM
This ICAEW Tax Representation sets out comments submitted on 6 February 2013 by the Tax Faculty in response to the HM Treasury and HM Revenue and Customs consultation on draft Finance Bill 2013 legislation concerning real time information penalties; includes introduction; who we are; key point summary; general comments; detailed comments on the draft legislation; Ten Tenets for a Better Tax System; examples where complying with the on or before rules may be difficult or impossible. (AI generated description)
2/6/13, 12:00 AM
Comments submitted by the Tax Faculty of ICAEW to HMRC in response to draft legislation on the temporary increase in the annual investment allowance published on 11 December 2012; outlines support for the increase but raises concerns about frequent changes, complex transitional provisions, timing issues, and IT and compliance costs; includes sections: introduction; who we are; major points; general points; specific points on draft legislation; Ten Tenets for a Better Tax System. (AI generated description)
2/1/13, 12:00 AM
Memorandum submitted on 22 February 2013 by the Tax Faculty of ICAEW in response to an HM Treasury call for evidence on the Government's review of the balance of competencies between the United Kingdom and the European Union in relation to taxation; covers EU competence in direct taxation, VAT, and the influence of the CJEU; includes introduction, who we are, main points, responses to consultation questions, and an appendix with the Tax Faculty's Ten Tenets for a Better Tax System; comments on proposals including the financial transaction tax. (AI generated description)
2/22/13, 12:00 AM
Comments submitted on 6 February 2013 by ICAEW Tax Faculty in response to HM Revenue & Customs Finance Bill 2013 draft clauses and Technical Note on amendments to the UK group relief rules; addresses proposed changes to s107 CTA 2010 following the CJEU decision in Philips Electronics UK Ltd (C-18/11) and recommends removing restrictions on losses of UK permanent establishments of EEA companies; contents include: introduction; who we are; our comments; ICAEW Tax Faculty Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
Memorandum submitted on 6 February 2013 by the ICAEW Tax Faculty responding to HM Revenue and Customs' December 2012 Vulnerable Beneficiary Trusts Summary of Responses and draft legislation published on 17 January 2013; addresses the definition of vulnerable beneficiary and small payment relaxations; raises concerns about applying s.32 Trustee Act 1925 restrictions to bereaved minors and 18-25 trusts; discusses protections in IHTA ss.71A and 71D, inconsistencies between intestacy and will trusts, and the scope of grandfathering for wills made before 8 April 2013; includes the Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/6/13, 12:00 AM
Representation by the ICAEW Tax Faculty responding to HM Treasury and HM Revenue and Customs on draft Finance Bill 2013 legislation concerning withdrawing a notice to file a self-assessment return; includes introduction; who we are; text of response to consultation; Tax Faculty's Ten Tenets for a Better Tax System. (AI generated description)
2/4/13, 12:00 AM