Global

Details

  • Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 4/4/2014

United Kingdom - New limit on “double tax” relief 

April 4:  The UK Finance Bill 2014 contains a new “double tax” relief anti-avoidance provision, which would apply from 5 December 2013.

The provision would limit double tax relief on loan relationship, derivative, and intellectual property non-trading credits to the UK tax payable on the “net” rather than gross income. The “net” income would be calculated after deducting debits, which are in respect of the same loan relationship, derivative or intellectual property as the non-trading credit.


The provision responds to avoidance schemes that seek to exploit mismatches between the amounts of UK and foreign income. However, the provision does not have a tax avoidance purpose test and, hence, appears to apply whenever the conditions are met.


Read an April 2014 report [PDF 873 KB] prepared by the KPMG member firm in the United Kingdom: Weekly Tax Matters (4 April 2014)


Also included in the report are the following topics:


  • Update on OECD BEPS Action plan 2: Hybrid Mismatch arrangements
  • OECD BEPS webcast – update on Country by Country Reporting
  • CJEU decision in Felixstowe Dock and Railway Co consortium relief case
  • CGT for Non-UK resident owners of UK residential property - corporate aspects
  • Offshore bareboat chartering draft legislation published
  • Theatre tax relief consultation launched
  • Le Rayon d'Or - CJEU judgment
  • Form 42: Last ever paper share plan annual returns due by 6 July
  • Measures in the Finance Bill affecting globally mobile workforce
  • DoTAS deadlines for RTI employers to submit AAG4 forms
  • Capital Gains Tax changes for non-UK residents on UK residential property
  • Reduced administrative burden for LLPs



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