• Service: Tax, Global Mobility Services, International Tax
  • Type: Regulatory update
  • Date: 6/6/2014

United Kingdom - Tax-transparent “authorised contractual scheme” investments 

June 6: HM Revenue & Customs (HMRC) published draft guidance on the tax treatment of investments in tax-transparent “authorised contractual schemes” (ACS).

The preamble to the draft guidance notes that the consultation on stamp duty land tax has not yet been published and that further guidance on capital allowances will follow.

HMRC also will consider whether the capital gains tax rules function as intended—although not explicitly stated, this is likely to be in relation to sections 99B, 103B and s103D TCGA 1992 which prevent accumulated income from being taxed twice.

The draft guidance will be of interest for those involved in investment management in the co-ownership version of the ACS.

Read a June 2014 report [PDF 675 KB] prepared by the KPMG member firm in the UK: Weekly Tax Matters (6 June 2014)

Other topics discussed in the KPMG report concern:

  • HMRC appeal in the Associated Newspapers Ltd. case
  • Taxpayer appeal in the Wiltonpark Ltd. case
  • Employment tax issues, including HMRC “customer survey” and FAQs on share incentives, guidance on taxation of workers supplied via intermediaries
  • Individual (personal) tax - HRMC sends letters to persons with low effective tax rates

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