Multinationals are looking differently at the UK and the new
choices it presents. Recent, significant tax reforms are
prompting many to reconsider the role that the UK can play in the
group's business activities and some have announced their
intention to return to or expand their activities in the UK.
Activities which in the past may have settled in Switzerland,
Luxembourg and the Netherlands can today be an ideal fit for the
UK. Meanwhile, investing in offshore operations from the UK
is significantly more attractive than it used to be.
So, what's changing and how should businesses react?
Our publication focuses on the current and emerging tax
opportunities that the UK now affords multinational groups, both UK
We cover UK tax changes including controlled foreign companies
(CFC) reform, Patent Box, above the line R&D and the reducing
corporation tax rate, and discuss what these changes mean for
businesses that have operations in the UK.
Of key importance are CFC changes which will bring more
flexibility to non-UK owned groups who use the UK as an
intermediate holding location, and UK-owned groups basing financing
We also provide guidance around what companies should be
considering now, and other areas to be aware of for groups who
might be considering expanding their presence in the UK.
Some time ago we wrote an article on the Foreign Account Tax Compliance Act ('FATCA') which says that although the FATCA tentacles are fairly intrusive, at the end of the day, it represents just another form for tax payers to complete.
Discretionary trusts, whenever created, and most other forms of lifetime trusts (other than bare trusts and qualifying trusts for disabled persons) established on or after 22 March 2006 are subject to what is known as the ‘relevant property' regime which imposes a charge to IHT on the capital value of the trust assets on each 10 year anniversary of the creation of the trust ..
The favoured tax status of foreigners planning not to stay in the UK on a long term basis (so called 'non-doms') became a hot topic in the run up to the UK General Election in May 2015, and one of George Osborne's early acts as Chancellor was to announce changes to the regime.
Many are aware that the principal income tax consequences of
expatriation are usually immediate – under the
‘mark-to-market' regime, a ‘covered
expatriate' is generally deemed to sell all of his property,
regardless of its location, on the day before he ceases to be
taxable as a US resident.
Some time ago we wrote an article on the Foreign Account Tax
Compliance Act ('FATCA') which says that although the FATCA
tentacles are fairly intrusive, at the end of the day, it
represents just another form for tax payers to complete.
Effective for the 2016 reporting year, the filing deadline for the Foreign Bank Account Report (FBAR) will be 15 April rather than 30 June. US citizens and residents abroad will receive an automatic two month filing extension to 15 June.