Finance Bill 2017

Finance Bill 2017

The Government published Finance (No. 2) Bill 2016-17 on Monday 20 March.

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The Government published Finance (No. 2) Bill 2016-17 on Monday 20 March. Our in-depth analysis on the key issues for businesses, individuals and employers can be found below.

 

 

Businesses

Hybrid and Other Mismatch rules amendments

Two amendments have been made to the hybrid mismatch rules to improve the way these rules will work.

Reform of the substantial shareholding exemption (SSE)

The conditions of the SSE have been relaxed significantly, in particular for companies owned by qualifying institutional investors.

Reform of CT Loss Relief

New restriction on use of carried forward losses. Most post-1 April 2017 losses no longer streamed and can be surrendered as group relief.

Patent Box – Cost Sharing Arrangements

Patent Box implications for companies involved in collaborative research and development (R&D).

New corporate interest restriction regime

From 1 April 2017 a new regime will restrict the tax deductibility
of interest-like expenses for UK companies.

Individuals

Exemption from attribution of carried interest

HMRC’s proposed solution to avoid double tax on carry in trusts distributed to a beneficiary may result in unexpected tax liabilities. 

Inheritance tax on UK residential property and related finance

UK residential property owned through certain non-UK structures and lenders providing debt finance will be subject to IHT.  

Life insurance policies: recalculating gains on part surrenders 

Policyholders will be able to apply to HMRC to recalculate gains on part surrenders where the normal rules would produce a wholly disproportionate gain.

Fundamental changes for non-UK domiciled individuals 

Non doms - are you ready for the fundamental change in the compliance landscape that starts on 6 April 2017?

Fundamental changes for non-UK domiciled individuals

Employers

Optional Remuneration Arrangements

The Finance Bill introduces legislation designed to remove the Income Tax benefits of Optional Remuneration Arrangements (OpRA). However, some question marks remain.

Off-payroll working in the public sector: reform of the intermediaries legislation (IR35)

The Finance Bill contains significant changes to the taxation of off-payroll workers in the public sector which are due to come into effect from 6 April 2017. 

Termination Payments – changes to Income Tax and National Insurance contribution (NIC) legislation

The Finance Bill contains significant changes to the taxation of termination payments which are due to come into effect from 6 April 2018.     

Changes to disguised remuneration legislation

The draft Finance (No 2) Bill 2017 published on 20 March 2017 contains some changes to the earlier legislative proposals on disguised remuneration published on 5 December 2016. 

Off-payroll working in the public sector: reform of the intermediaries legislation (IR35)

Off-payroll working in the public sector: reform of the intermediaries legislation (IR35)

Spring Budget 2017

Expert insight into the Chancellor's statement.

 
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Finance Bill 2017 Draft Clauses

KPMG’s Commentary provides an overview of the draft clauses and insight into the measures both those of general interest and for specific groups.

 
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