Finance Bill 2016-17 – amendments published

Finance Bill 2016-17 – amendments published

A number of amendments have been proposed to this year’s Finance Bill.

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On 14 June 2016, the Government published a number of amendments to Finance Bill 2016-17, along with explanatory notes. The Bill will next be considered at Committee Stage, with parts of the Bill to be considered by a Committee of the whole House on Monday 27 June and Tuesday 28 June 2016. The remainder will be considered in a Public Bill Committee, the dates of which have not yet been announced, but will be concluded by 14 July 2016.

The amendments include:

Investors’ Relief

The amendments extend the availability of Investors’ Relief to unpaid directors, those who take up paid employment after 180 days and trustees of certain trusts. For more on this, see our detailed article.

Serial Tax Avoidance (STA)

The amendments ensure that tax avoidance schemes pursued through either a partnership or a controlled company are brought within scope. Should either a partnership or a controlled company undertake a tax avoidance scheme which is subsequently defeated, either the partners in the partnership or those controlling the company will be deemed to have participated in a defeated tax avoidance scheme for the purposes of the STA legislation and so will also receive warning notices. The objective is to ensure that the STA provisions cannot be circumvented by shifting tax avoidance schemes into related or controlled entities.

General Anti-Abuse Rule (GAAR)

Amendments have been made to Clauses 144, 145 and 146 of the Finance Bill which seek to ensure that:

  • The GAAR procedural changes work as intended;
  • The GAAR Penalty works as intended in situations where the return, claim or other document that is counteracted was submitted by someone other than the taxpayer; and
  • Abusive arrangements concerning National Insurance Contributions (NICs) are subject to the same changes as the tax rules.

There are also minor amendments in the following areas:

  • Travel expenses of workers providing travel expenses through intermediaries;
  • Employee Share Schemes;
  • Entrepreneurs' Relief;
  • Promoters of Tax Avoidance Schemes;
  • Taxable benefits: application of Chapters 5 to 7 of Part 3 ITEPA 2003; and
  • Employee Shareholder limit on exemption.

In addition, a cross-party group of backbench MPs have proposed an amendment which would require large multinational companies to include their country by country (CbC) reports in the publication of their tax strategies. While non-Government proposals do not usually pass, the amendment may provoke further discussion on public CbC when the clauses on tax strategies for large businesses are debated.


For further information please contact :

Kayleigh Havard 

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