The amendment covers foreign dividends, which may only come into tonnage tax if they are paid out of profits that are subject to tax.
This year’s Finance Bill contains a new optional ring-fenced regime which allows companies to elect to have taxable profits from shipping activities calculated by reference to the tonnage of qualifying ships, instead of by reference to commercial profits.
Although the tonnage tax regime already contains a number of provisions to protect against abuse, under the current proposals dividends from foreign companies may come within the tonnage tax regime, regardless of whether or not the profits from which those dividends emanate have been taxed.
The government claims it does not want to allow the possibility it could be used as a tax-efficient route for repatriating money from countries that do not tax shipping activities. This amendment removes this possibility.
HMRC has outlined a change in VAT policy to the treatment of dwellings that have been formed from either the construction of new buildings, or from the conversion of non-residential buildings
Let us hope that valuable asset protection vehicles are not made prohibitively burdensome or abolished in the desire to “simplify” IHT
The government is pressing ahead with changes to the way it taxes individuals with a foreign domicile
I will feel slightly awkward when I write to the client who is about to receive a large invoice from the PAYE expert, offering him the fee protection going forward