Transcript Document
Outlook for the UK
Economy
Winter Update
5 December 2014
Speaker:
Professor Joe Nellis
Pro-Vice-Chancellor & Director
School of Management
Cranfield University
State of the Nation
Upward revisions to GDP in recent months
- resulting in a £1.7bn bill demanded by EU (reduced?)
UK GDP is now well above the pre-crisis peak
in Q1 2008
- and is set to grow by around 3% this year
Growth is looking fairly well balanced
- with investment growth accounting for a significant share
Pace of growth will ease in 2015
- easing of business and consumer confidence
- domestic political uncertainty
- international factors, e.g. Japan and Eurozone!
GDP Quarterly Growth Rate
Source: www.tradingeconomics.com | UK Office for National Statistics
GDP Annual Growth Rate
Source: www.tradingeconomics.com | UK Office for National Statistics
CBI Business Confidence Index
Government Finances
The solid economic recovery has NOT yet boosted
government tax revenues
- net government borrowing is UP 6% on last year
- and was forecast to be 10% LOWER
Income tax receipts are disappointing due to:
- shift to lower paid work for many
- rises in the tax-free personal allowance
- some one-off factors
Likely to be even tighter fiscal squeeze in the coming
years regardless of Election outcome
- if deficit reduction plans are to be met
Austerity continues
Government Finances
By 2018/19, day-to-day government spending
as a share of GDP is forecast to fall to its
lowest level since official records began in 1948!
If Health, Education and Overseas
Development Aid spending remain
protected, then major cuts are
inevitable across other departments
Budget Deficit (as % of GDP)
Source: www.tradingeconomics.com | Eurostat
National Debt (as % of GDP)
Source: www.tradingeconomics.com | UK Office for National Statistics
10 year Government Bond Yields
Source: www.tradingeconomics.com | United Kingdom Department of Treasury
Monetary Policy
Base rate still on hold at 0.5% - for 5 years!
But a rise is expected in 2015 (?)
- as wages start to rise (slowly…)
- alongside a 3% rise in minimum wage rate
- and as firms begin to report recruitment difficulties
A global liquidity glut is keeping long-term rates very low
- 10 year bond yields are just over 2%
- but should start to rise gradually year-by-year
So..... no big surprises ahead!
Prices & Wages
Core inflation grew by 1.3% in October
- below Bank of England 2% target for almost a year
Key factors:
-
falling key food prices
lower oil pushing down petrol prices
weak underlying demand pressures
sterling strength against the euro
Low stable inflation looks set to continue
- and may fall below 1% soon
A letter from Mark Carney…….?
Prices & Wages
Wages will continue to recover slowly in 2015
- and will be partly offset by productivity
- as corporate investment continues to grow
Sustainable long term
economic growth coupled
with low inflation....
Boring but good!
Inflation Rate
Consumer Demand
Key component of GDP
- but has been punching below its weight in recent
quarters as debt reduction continues
- likely to continue to do so as wages rise slowly
But “real” pay increases will start to come through in
2015 to support stronger spending & confidence
Employment levels continuing to rise
- and unemployment continuing to fall
Unemployment Rate
Source: www.tradingeconomics.com | UK Office for National Statistics
The Housing Market
Signs are that the market is beginning to cool
- Reactions to various policy interventions
o Mortgage Market Review
o Tougher affordability checks
House price inflation moderating
- but not everywhere!
Positive factors:
- strong population growth
- improvement in household incomes
- easing of credit availability
The Housing Market
Negative factors:
- expected rise in interest rates
- squeeze on affordability
(especially London and southern regions)
- restriction on size of mortgage loans to maximum of
4.5 times income to no more than 15% of new
mortgage lending by any bank
- checks on borrowers’ ability to pay at interest rate 3%
above current level
Average UK House Price
Source: Nationwide
UK House Price Movements (Q on Q)
Source: Nationwide
UK House Price Movements (Y on Y)
Source: Nationwide
Affordability of Housing
Source: Nationwide, ONS
Where Are We Going?
Forecasts for the Economy +
(% changes on previous year)
Forecasts
2012 2013 2014 2015
2016 2017 2018
GDP
Consumer Spending
0.7
1.1
1.7
1.6
3.1
2.1
2.4
2.3
2.3
2.2
2.5
2.0
2.5
1.8
Fixed Investment
Net Govt. Borrowing*
0.7
7.2
3.2
5.6
9.2
4.9
6.5
3.9
7.7
2.4
7.9
1.0
6.2
0.1
Average Earnings
2.4
1.4
1.1
2.1
2.8
3.3
3.8
Inflation (CPI)
Bank Rate
2.8
0.5
2.6
0.5
1.6
0.5
1.3
1.1
1.7
2.1
2.1
3.1
2.2
3.8
+ Source: ITEM Club October 2014
* Fiscal years, as % of GDP
Outlook
Slowdown in economy growth in 2015 due to
political uncertainty at home and abroad
Low inflation looks set to stay!
falling commodity prices
Interest rates will increase only slowly
A Goldilocks Economy….
-
not too hot…
not too cold…
just about right!
Q&A
Winter Update, Autumn Statement
and planning for 2015 for SMEs
Presented by:Bob Trunchion, Tom Byng and Ricky Noimark
December 2014
© MHA MacIntyre Hudson 2014
Running Order…
• Introduction
• Topical tax issues regarding SMEs
– How is Corporation tax moving:
• Patent Box Taxes and R&D
• Capital Allowances
–
–
–
–
ATED
Cash extraction and Pensions Freedom
Some topical VAT & Duty Points for SME
The Autumn Statement
• Some Pre Election Points
•Q&A
© MHA MacIntyre Hudson 2014
Draft Finance Bill Process &
the Autumn Statement
• Historically, we had Autumn Spending announcements and
Spring Budget Statements
• Then moved to an autumn Budget under Mr Clarke
• Then Pre Budget Reports under Mr Brown with a Spring Budget
• Return to the Autumn Statement under Mr Osborne with draft
Finance Bill clauses (Legislation Day)
• Why – Complexity of Legislation…….. and consultation(?)
• So tax and spending announcements at this time to include
anti-avoidance, some new measures and some of next year’s
income tax and NIC rates/allowance details
• This year’s timetable ?
– 3 December 2014 - Autumn Statement
– Draft Finance Bill 2014 – 10 December 2014 (Legislation Day)
– March 2015 Budget
but the election on 7 May…….
© MHA MacIntyre Hudson 2014
Legislative Process
• Proposals from Budget and FA 2013 and 2014 that
come into effect from April 2015
• Proposals from this Autumn Statement coming into
effect April 2015
• Proposals from Budget and FA 2014 and 2015
effective immediately
• Proposals from Budgets that never become
effective
• Process creates some sense of déjà vu
© MHA MacIntyre Hudson 2014
Autumn Statement 2014
Government spending 2014/15
© MHA MacIntyre Hudson 2014
Autumn Statement 2014
Government receipts 2014/15
© MHA MacIntyre Hudson 2014
Autumn Statement 2014
Tax yields – from 2014/15
Receipts
2014/15
2015/16
2016/17
2017/18
2018/19
% shift
Income tax
166.5
176.8
189.2
201.3
213.2
28.04%
NIC
110.9
115.0
126.1
132.0
138.2
25.63%
VAT
110.7
115.0
119.2
123.3
127.7
15.35%
CT
41.4
42.3
42.6
44.5
45.9
10.86%
CGT
5.4
6.7
7.5
8.2
9.0
66.66%
IHT
3.9
4.3
4.9
5.4
5.8
48.71%
© MHA MacIntyre Hudson 2014
• Falling CT Rates
FY2011
FY2012
FY2013
FY2014
FY2015
• 26%
• 24%
• 23%
• 21%
• 20%
Marginal rate between £300k and £1.5 million:
FY2011
FY2012
FY2013
• 27.5%
• 25%
• 23.75%
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FY2014
• 21.25%
FY2015
• 20%
• Associated Companies are no longer relevant with
single 20% CT rate from 2015?
• Currently divide Upper and Lower limits by number
of associated companies (FY2014)
• New 51% subsidiary definition in FA 2014 –
1/4/2015
• Upper £1,500,000 limit (and Associated Company
splitting thereof still relevant for Quarterly
Instalment Payments (QIP)
• Serious cash flow impact first year that applies
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Quarterly Instalment Payments
• Payments due , EG y/e 31 December 2014:
• 25% 6m and 13 days after start of AP 14 July 2014
• 50% 3m after 1st instalment
14 Oct 2014
• 75% 14 days after end of AP
14 Jan 2015
• Balance - 3m and 14 days after AP 14 April 2015
• Instead of 100% due 9 months after end of AP - 1
October 2015 - Significant impact on cash flow
• Still worth minimising number of Associated
companies to stay out of QIPS (dormant subs OK)
© MHA MacIntyre Hudson 2014
Patent box
10% tax rates
Granted patent
Registered in
(or pending)?
the UK or EPO
Outright ownership
June 2016
Closed to new
entrants
OR
Exclusive License
(by reference to territory)
June 2021
Active
Development
Ownership
Condition
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Abolished
Patent box
Patent box 2.0
R&D must have taken place in the UK
Will impact
• Non UK group companies doing R&D
• Foreign HQ groups licensing to UK
Tracking and tracing?
Do you benefit from any patents where the R&D was performed
overseas?
Elect into
Patent Box 1.0
before June
2016
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5 years
guaranteed
R&D tax relief
More free cash!
Seek to achieve a scientific
or technological advance
AND
Resolution of scientific or
technological uncertainty
Two regimes:
SME
Large
Benefit
Benefit
i.e. 26% cash tax saving (up from
225% / 25%)
• 33.35% (was 32.6% and 24.75%)
cash back if loss making
profitable
• 8.8% (was 8%) cash back if not
tax paying
• 230% tax deduction if profitable,
• Above the line
• 8.8% (was 8%) tax saving if
• 500 employees, AND
• €100m turnover, OR
• €86m balance sheet
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R&D tax relief
SME scheme examples
Profitable,
with no
R&D relief
Profitable,
claiming
R&D relief
Loss making,
with no R&D
relief
Loss making,
claiming R&D
relief
5,000
5,000
800
800
R&D expenses
(1,000)
(1,000)
(1,000)
(1,000)
Other expenses
(1,000)
(1,000)
(1,000)
(1,000)
3,000
3,000
(1,200)
(1,200)
Turnover
Profit / (loss)
Tax relief
(1,300)
(1,300)
Loss surrender
Taxable profit
Tax payable
Losses to carry
forward
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2,300
3,000
1,700
600
340
(334)
1,200
200
R&D tax relief
Large scheme examples
Turnover
R&D expenses
Profitable,
with no
R&D relief
Profitable,
claiming
R&D relief
Loss making,
with no R&D
relief
Loss making,
claiming R&D
relief
5,000
5,000
800
800
(1,000)
(1,000)
(1,000)
(1,000)
ATL credit
Other expenses
Profit / (loss)
Tax charge
110
(1,000)
(1,000)
(1,000)
(1,000)
3,000
3,110
(1,200)
(1,090)
600
622
ATL credit
Tax payable
Losses to carry
forward
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110
600
(110)
(88)
512
(88)
1,200
100
+22 tax credit
R&D tax relief
Examples
As well as ‘obvious’ R&D…
• Software
• Software developers
• New operating systems in ANY industry
• e.g. travel agent, window manufacturer
• Video games development
• Manufacturing
• Machine development / process improvements
• Product development
• Property and construction
• Architects
• Building design services
• Food
• Improved taste, texture
• Reduced sugar, salt, fat
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Capital allowances and AIA
• On first
– £50,000 to March 2010
– £100,000 to March 2012
– £25,000 to December 2012
– £250,000 to March 2014
– £500,000 to December 2015
– £25,000 onwards??
• Free to allocate AIA between companies and types of expenditure
– 8% v 18%
– Tax rates
– Date of expenditure
© MHA MacIntyre Hudson 2014
AIA
• Date of expenditure crucial
• Easy for the next year
• However…
• Example
– New machine purchase for £500,000
– Buy pre 31 December 2015, potential max AIA of
£500,000 (if 31 December 2015 year end)
– Buy post, max AIA = £25,000 (could be less)
• Need to seek advice in advance!
© MHA MacIntyre Hudson 2014
AIA Example 1
Example 1
– Year ended 31 March 2016
– Maximum allowance: £381,250 (being 9/12 x £500,000 =
£375,000 plus 3/12 x £25,000 = £6,250).
– New machine £350,000
– Buy pre 31 December 2015, max AIA = £381,250
– Buy post, max AIA = £6,250
© MHA MacIntyre Hudson 2014
Example 2
More realistic example
– Year ended 30 June 2014
– Maximum allowance: £312,500 (being 9/12 x £250,000 =
£187,500 plus 3/12 x £500,000 = £125,000).
– New machine purchased on 30 April 2014 for £500,000
– AIA = £312,500
– Shorten AP to 31 March 2014
– Expenditure in 31 March 2015 AP, where AIA = £500,000
© MHA MacIntyre Hudson 2014
Fixtures in Building
Typical proportions:
• Air conditioned office 20% - 40%
• Hotel
20% - 35%
• Modern office
10% - 25%
• Industrial unit
5% - 20%
• Shop shell
2% - 8%
© MHA MacIntyre Hudson 2014
Fixtures Post April 2014
Key issues
• Sellers
– Ensure CA history in order
• Purchasers
– Ensure solicitor agrees CA value within sale and purchase
contract
• Most importantly, get advice early!
© MHA MacIntyre Hudson 2014
ATED
Includes Limited Companies, LLP with corporate partner
and Collective Investment Scheme
Exemptions only for charitable bodies, otherwise need to
file a return even if you qualify for a relief (e.g. property
developer, buy to let…)
Reporting date is annually on 30 April unless….
…mid year acquisitions need to be reported within 30
days
© MHA MacIntyre Hudson 2014
ATED – what to look for……
April 2015 and then April 2016
• Annual charge – Companies etc.
•Property ≥ £500,000 from 2016
•Current rates (subject to index linking)
£0.5m - £1m
£3,500
£1m - £2m
£7,000
£2m - £5m
£23,350*
£5m - £10m
£54,450*
£10m - £20m
£109,050*
£20m +
£218,200*
* New rates announced in Autumn Statement 2014
© MHA MacIntyre Hudson 2014
More on ATED
Failure to register – normal HMRC penalty regime ….
£100 late filing
3 months - £10 a day for 90 days
6 months – Greater of 5% or £300
12 months – Greater of 5% or £300
More than 5% of tax
if deliberate
Consultation underway on simplifying reporting requirements
Plan in advance for April 2015 changes
If you do not file a return, any CGT gains from ATED properties will
be taxed at 28%!
© MHA MacIntyre Hudson 2014
Extraction of company profits
Methods generally used to extract profits:
• Dividends
• Salaries and bonuses
• Benefits in kind
• Pension contributions
• Loans from the company
• Interest on loans to the company
• Rent from personally owned assets
© MHA MacIntyre Hudson 2014
Pensions Freedom
© MHA MacIntyre Hudson 2014
Pensions Freedom
Overview:
• Permissive statutory override of scheme rules to allow
new flexibility
• Free to transfer between defined contribution schemes
• But scheme rules may prohibit – watch!
• Tax rules relaxed to allow more innovative products
• Anti-avoidance to prevent pension recycling - £10,000
cap on contributions if in some types of drawdown
• Increase minimum age to access pension to 57 – 2028
• Reduce 55% charge on death to zero (<75) – or MR IT
(>75)
© MHA MacIntyre Hudson 2014
Pensions Freedom
another point:• Treasury expects to net additional £1bn tax receipts
from earlier drawdown over next two years.
• £1bn or more per year thereafter
• This means a grey injection of about £2.5 billion of
extra spending into the economy……..
© MHA MacIntyre Hudson 2014
Pensions Freedom
• Are the changes positive?
– far greater flexibility – many more options for people
– remove complexity! (?)
– The Government is treating us like adults! Will people blow
their pension fund and rely on the State?
– But what about Australia?
– Individuals will have right to free and impartial advice (note –
now guidance)
– Where will proper advice come from?
© MHA MacIntyre Hudson 2014
Death and Social Care
• Govt. changing the tax charge on funds in drawdown
product at death or uncrystallised after age 75
• Accepted that current rate of 55% is too high
• For Social Care - these products will be treated similarly
to current drawdown products - any capital held in
drawdown product excluded from capital means tests
• Those who choose to draw down full pension pot quickly
and manage it directly will need to consider how this
could affect their entitlement to welfare and social care
support
© MHA MacIntyre Hudson 2014
Passing your pension on…
• HM Treasury release 29 September 2014 – legislation and
Autumn Statement confirm going ahead!
• 55% tax rate on death goes from 6 April 2015
• For pension funds (not DB) untouched or in flexi access
• Death prior to 75 – passes tax free to beneficiary
• Death over 75 - passes to beneficiary – extraction
thereafter at their MR (eventually – after consultation) but
fixed 45% initially from 6 April 2015
• Think of the planning opportunities!
• Watch £1.25 Million life time limit always
© MHA MacIntyre Hudson 2014
Passing your pension on…
• Autumn Statement – Unlikely for a new
administration to be able to put the genie back in
the bottle!
• Not all DC schemes will allow flexibility
• Watch State and other DB schemes
• Then get it in place after 6 April 2015?
© MHA MacIntyre Hudson 2014
MOSS – Mini One Stop Shop
• From 1 January 2015, supplies of telecommunications,
broadcasting and electronically supplied services made
by EU suppliers to private individuals and non-business
customers will be taxable in the Member State of the
customer.
• Digital Services may include the following:
Broadcasting – TV/Satellite or radio programs
Telecommunication services - includes fixed and
mobile calls and connection to the internet
Electronic-services – sales of apps, music
downloads, e-books, on-line auctions, gaming, video
on demand, provision of information, sale of
advertising space and other downloaded
applications
© MHA MacIntyre Hudson 2014
Why change
• To ensure the services are being taxed where consumed
• Why has HMRC introduced MOSS?
- As a way of helping taxpayers
- Without it B2C suppliers may need to register in many countries
- A single on-line return will reduce costs and simplify the burden
© MHA MacIntyre Hudson 2014
Why change
• Registration now available
• Quarterly returns due by the 20th of the following month
• 1 separate page per member state country
• 1 single payment made
• HMRC distributes to other authorities
• Only output tax is accounted for on the MOSS return
• Keep records for 10 years
• Optional scheme can deregister but can’t use again for 6 months
© MHA MacIntyre Hudson 2014
E-service VAT
Examples
Bob runs an internet dating agency
Jaqui is an Irish resident and pays £100 a month
Issues
December 2014 sub is £100 inc UK VAT at 20%
Bob pays 16.67 on his UK VAT return
January 2015 sub is £100 inc VAT at 23%
Bob pays 18.70 via MOSS
© MHA MacIntyre Hudson 2014
E-service VAT
Example 2
Brendan is a musician and sells music for Ringtone Apps via a license agreement
to a German company
The German Company sells downloads to final consumers
Issues
Brendan is in a B2B transaction and is not affected by the changes
But what if Brendan remained contractually liable…….
© MHA MacIntyre Hudson 2014
Customs Codes - Some Surprises
• Two (potentially) significant changes included
• Change to the concept of a retail sale in a customs warehouse
• Proposed Implementing Act abolishes the earlier sale concept
© MHA MacIntyre Hudson 2014
The Earlier Sale Concept
US manufacturer sells
to Sales co
UK customer
Goods
Settlement
$50,000
Invoice
$20,000
Invoice
$50,000
US sales co sells to
Swiss sales co
Invoice
$30,000
Swiss sales co sells
to customer
For Customs Duty value can be 1st sale
now looking to abolish - needs to be
© MHA MacIntyre Hudson 2014
Issues that can affect you if you import
• Is this necessary?
• Who is responsible?
• We don’t pay any duty
• Do we import anything?
• Its not my job!
• Just get it here!
• Just get it there!
• We’ve always done it this way!
• Our agent handles everything!
• We called Customs – its ok!
© MHA MacIntyre Hudson 2014
FATCA Myths
with thanks to STEP, ICAEW & Law Society
• MYTH 1
• It doesn’t apply to me, I’m British
• MYTH 2
• It doesn’t apply to me because there are no US
connections (indicia), assets or income
• MYTH 3
• It doesn’t apply to me because it is worth less than
$50,000/$250,000/$1,000,000
• Me = An entity – company, LLP, Trust,
partnership……
© MHA MacIntyre Hudson 2014
FATCA FACTS
• The non US world is split into entities and non entities! (?)
• If you are an entity, you are either a Financial Institution
(“FI”) or a Non Financial Foreign Entity (“NFFE”)
• If you are an FI (often a trust), you will need to register
with the IRS and get a“GIIN” and report (usually) to HMRC
but be able to give your GIIN to banks and investment
advisors – before they can do business with you.
• NFFEs need to understand their FATCA status and be able
to prove it to banks etc before they can do business with
you.
– NFFEs can be active (or trading) – no problems
– NFFEs can be passive – need to tell bank etc of US connections
© MHA MacIntyre Hudson 2014
Autumn Statement 2014
Pre-election tax landscape… 07.05.15… One Budget to go!
Some manifesto promises to date:
• £50K higher rate threshold
• Personal allowance pledges
• The “Mansion Tax” issues
• CGT proposals
• 50% v 45% Income Tax
• Anti-avoidance/tackling tax fraud
© MHA MacIntyre Hudson 2014
BEPS & Tax Avoidance in the News
Starbucks to move European HQ to UK 16 April 2014
Starbucks said the UK was its fastest growing and largest market in Europe
Starbucks is to move its European head office from Amsterdam to London by
the end of the year, following a row over corporate tax avoidance.
"This move
will
mean we pay more tax in the UK," the company said
© MHA MacIntyre
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© MHA MacIntyre Hudson 2014
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© MHA MacIntyre Hudson 2014
And Some Figures……
From HMRC
• Tax Gap - £34Bn which is 6.8% of total!
–
–
–
–
–
–
£3.1Bn
£4.1Bn
£5.9Bn
£5.4Bn
£7.1Bn
£8.4Bn
–
–
–
–
–
–
Avoidance
Evasion
Black Economy
Criminality
Errors, Mistakes, Failure to collect tax
The rest…..
• Where does avoidance fall in the list?
© MHA MacIntyre Hudson 2014
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We don't pay taxes. Only the
little people pay taxes
Leona Helmsley
American property tycoon, New York Times (12 July
1989); Newsweek (24 July 1989) p11
Helmsley later served 19 months in prison for tax evasion.
76
© MHA MacIntyre Hudson 2014
Some Other Autumn Statement
Points
• ISAs to retain status on transfers caused by death
(interspouse = no IHT either, watch IHT otherwise)
• Business rates – relief for SMEs
• Incorporation restrictions
• Employment Allowance extended to carers
• Non Domiciled persons to pay more tax
• APD reduced for children
• SDLT on residential property
© MHA MacIntyre Hudson 2014
SDLT on residential property
• From 4 December 2015:
• Slabs gone – bands in….
• 0 - £125,000
• £125,001 - £250,000
• £251,000 - £925,000
• £925,001 - £1,500,000
• £1,500,000+
© MHA MacIntyre Hudson 2014
Nil
2%
5%
10%
12%
Consequences
Type of Home
Av Help to Buy
Av Family Home
Average London
Larger Home
© MHA MacIntyre Hudson 2014
Value
£
125,000
SDLT
£
Old 1,850
New 1,200
275,000
Old 8,250
New 3,750
510,000
Old 20,400
New 15,500
2,100,000 Old 147,000
New 165,750
Change
£
-650
-4,500
-4,900
+18,750
Some Pre Election Planning?
• Entrepreneur’s Relief from CGT
– Today, the first £10M of an entrepreneurial gain is taxed at
10% rather than 28%
– PAC say £2B more relief given than expected
– Will there be restrictions in future?
– Should we crystallise today if we are going to sell anyway?
• IHT Planning
– What will happen to BPR?
– Trust Tax likely to change
– Should we do it today?
• Income Tax Planning
– Should we take income today if 50% rate happens tomorrow?
© MHA MacIntyre Hudson 2014
Q&A
Thank you for coming.
Any questions?
Contact:
Tom Byng (Tax Partner) – [email protected]
Ricky Noimark (Tax Manager) – [email protected]
0208 446 0922
www.macintyrehudson.co.uk
Download ‘MHA tax app’
© MHA MacIntyre Hudson 2014
Disclaimer
This information is based upon current legislation, which is subject to change.
Whilst every effort has been made to provide accurate and up-to-date information, it
is recommended that you consult us before taking, or refraining from taking, action
based on matters discussed. We accept no liability for any loss suffered.
MHA MacIntyre Hudson is a firm of Chartered Accountants, Tax and Business
Advisers, regulated by the Institute of Chartered Accountants of England and Wales.
MHA MacIntyre Hudson is a founder member firm of MHA, a UK wide association of
Chartered Accountants, and a member of Baker Tilly International, a preeminent
network of accountancy firms worldwide
© MHA MacIntyre Hudson 2014