Finance Act 2014 Lexis®PSL Tax Analysis

Finance Act 2014Lexis®PSL Tax Analysis

Commentary on the impact of the most notable provisions of the Finance Act 2014

Lexis®PSL TAX

Contents

1 Finance Act 2014 - what it means for business and enterprise Mark Baycroft, Chantrey Vellacott

2 Finance Act 2014 - the impact on the financial sector Angela Foyle, BDO

4 Finance Act 2014 - what it means for employment taxes Emma Bradley and Charlotte Williams, Veale Wasborough Vizards LLP

6 Finance Act 2014 - what it means for pensions taxes Richard Lee, Wragge Lawrence Graham & Co

7 Finance Act 2014 - what it means for private client lawyers Kate Davies, Wedlake Bell

8 Finance Act 2014 - what does it mean for incentivised investment into social enterprises? Nathan Williams, Natalie Stoter

10 Finance Act 2014 - what it means for real estate lawyers Simon Yeo and Matthew Roach, KPMG

12 Finance Act 2014 - what it means for environment lawyers Alex Ibrahim, Nabarro

13 Finance Act 2014 - tackling tax avoidance and evasion? Catherine Robins, Pinsent Masons

14 Finance Act 2014 - tackling tax administration Keith Gordon, Atlas Tax Chambers

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Finance Act 2014 | LexisPSL Tax Analysis Get a free trial of LexisPSL Tax at lexisnexis.co.uk/fa14/trial

After the Finance Act 2014 received Royal Assent on 17th July 2014, the LexisPSL Tax News Analysis team sought expert opinion on its most notable provisions. This document collates opinions from leading experts in a variety of areas into an overall guide on the tax implications of the new Finance Act.

This commentary originally appeared in LexisPSL Tax, which you can find information on at the end of this document.

Interviews conducted by Kate Beaumont, Neasa MacErlean, and Rachel Moloney.

The views expressed by our Legal Analysis interviewees are not necessarily those of the proprietor.

Keep up to date with the latest Corporate Tax news from our LexisPSL Tax team @LexisUK_Tax. You can also get the get broader legal and tax news @LexisUK_News.

Finance Act 2014 - what it means for business and enterprise

How will the Finance Act 2014 (FA 2014) impact business and enterprise? Mark Baycroft, director at Chantrey Vellacott, London, discusses the implications of the new legislation.

What are the key developments in business and enterprise as a result of the FA 2014 receiving Royal Assent?For the changes in tax legislation that provide annual tax incentives to business and enterprise - for example increased research and development (R&D) tax credits for SMEs and the increase in the annual investment allowance - Royal Assent has simply rubber stamped the changes that were announced at or before the Budget.

While this could be said to bring greater certainty to the business community, most of the changes take effect from the start of the tax year and, on the grounds that no substantive changes were expected to any of these provisions, it is unlikely that many businesses held off decisions until Royal Assent and instead relied on the Budget announcements and previous consultation documents.

For those changes in tax legislation that provide tax incentives for one off or infrequent events, Royal Assent has given certainty on the tax treatment of these events to businesses and entrepreneurs, who may have waited to make decisions on share schemes and employee ownership until Royal Assent was received.

Unfortunately, for those who are caught by the introduction of new anti-avoidance legislation, the receipt of Royal Assent has in many cases brought greater uncertainty in terms of their overall tax position and, in many cases, greater concern to the business community, in terms of their cash flow.

Dealing first with those operating a mixed partnership structure, there are some subjective elements in the anti-avoidance legislation that may make it difficult to determine the correct tax rate to apply to profits, and hence the correct amount of tax to pay in future.

Secondly, for those who have entered into avoidance arrangements that are potentially within the scope of the general anti-abuse rule (GAAR), disclosure of tax avoidance schemes (DOTAS) or follower notices there is the possibility of receiving an accelerated payment notice (APN) at an unknown time in the future. Other commentators have written extensively on the role of HMRC as judge, jury and executioner under this legislation, but it is the latter role that could result in the greatest uncertainty as businesses face the choice between:

• choosing to invest now and risking insufficient cash flow to make payment under an APN, or

• holding back funds to make payment under an APN and making insufficient investment for the future development of the business

Are there any changes in the provisions since the draft bill was published?There have not been many changes to the substantive purpose of the legislation referred to in the previous answer, and no new provisions that affect the majority of businesses.

For those enterprises that may be looking to implement the employee ownership model, capital gains tax relief will be withdrawn and a gain will revert to the original shareholder if the model is abandoned within the twelve months following the tax year it is implemented. Any later abandonment of the model will result in a charge on the trustees of the Employee Ownership Trust.

http://www.lexisnexis.co.uk/fa14/trial

http://www.legislation.gov.uk/ukpga/2014/26/contents/enacted

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For those who may receive follower notices, the grounds on which the 50% penalty can be appealed against have been spelt out in detail.

There have been many minor changes to definitions and references, but none of these have a substantive impact on the legislation.

Why were these changes made?The substantive changes were made to stop the obvious avoidance of tax by reinforcing the deterrent effect of the legislation, and to provide clarity to the taxpayer on when an appeal can be made. The latter may also be an attempt to modify taxpayer behaviour and deter frivolous appeals.

The minor changes were made to bring consistency with other areas of legislation and to make the overall legislative package clearer and less ambiguous.

Do you think they achieve their purpose?The changes certainly achieve the intended amendments to the legislation. However, if the purpose is to provide a deterrent effect that modifies taxpayer’s behaviour then only time will tell. Recent statistics on the total revenue from the annual tax on enveloped dwellings (ATED) show that this has not had a deterrent effect on taxpayers’ behaviour, but anecdotal evidence on pre-owned assets tax suggests that this had a significant impact on taxpayer behaviour.

Were there any other changes you think should have been made?The weight of opinion against the follower notices and APN regime demonstrates that changes should have been made. Ignoring any debate over the rights and wrongs of tax avoidance and the multiple roles of HMRC, a ‘one size fits all’ approach to the payment regime does not take into account the different financial positions of businesses and the fact that their current position may be significantly different to when they undertook the avoidance that is now subject to an APN.

Taxpayers who wish to ‘make good’ may find that they do not have the financial means to do so immediately, so flexibility in the payment system without additional penalty should have been included to seek to maximise the amount of cash collections rather than merely penalise.

How does this impact your clients? Clients who can benefit from tax incentives will see increased claims for R&D tax credits and capital allowances. The firm’s specialist R&D team will be looking to assist SME businesses with cash flow by maximising their claims for R&D tax credits, and we will be advising clients on the optimal timing of capital expenditure.

Clients who have entered into tax avoidance arrangements in the past will be understandably worried about the possibility of receiving an APN. We will be seeking to establish good working relationships with the relevant promoters so that we can keep our clients informed of developments with their particular arrangement and explain the options available to them in these uncertain times.

Mark Baycroft is a director of Chantrey Vellacott, specialising in business tax and capital markets for owner managed businesses and the property and construction sector.

Finance Act 2014 - the impact on the financial sector

How could the Finance Act 2014 (FA 2014) affect the financial sector? Angela Foyle, partner in BDO’s corporate tax team, specialising in financial services, explains the key changes and whether or not they will achieve their objective.

Original newsThe presumption of self-employment for salaried members of limited liability partnerships (LLPs) is removed to tackle disguised employment relationships through LLPs. In addition, changes are made to the pay as you earn (PAYE) system to prevent income tax avoidance by both offshore and onshore employment intermediaries. In addition to other measures announced at Budget 2014 and Autumn Statement 2013 being implemented, part of the stamp duty reserve tax (SDRT) application to unit trusts and open-ended investment companies (OEICs) is abolished.


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What are the key developments in the finance sector as a result of FA 2014 receiving Royal Assent?A couple of the key changes relate to partnerships and the Code of Practice on Taxation for Banks.

Many alternative investment fund managers and other investment managers use a partnership structure and FA 2014 will have a significant effect on them. Their businesses will not necessarily be changed. However, the changes may impact taxation on remuneration. This could have a knock on effect on how they structure themselves - many used LLPs. Under the changes, some people who were previously treated as partners would now become employees. There are also changes to partnerships which have corporate members as well as individual members. Under previous rules corporate members would have had their income that was being taxed at lower, corporate rates. The changes mean that where partnership profits are received by the corporate member, the corporate member’s profits will be subject to income tax rates unless (broadly) no partner or person providing services in the firm benefits from that income-ormolu, can show that the profits represent an arm’s length value for services provided by the corporate member or that a fair commercial return was being received on the capital provided by the corporate member.

The new provisions relating to the Code of Practice on Taxation for Banks provides for the public naming and shaming of banks that have signed up to the code, but have engaged in unacceptable tax arrangements.

There is also the abolition of SDRT on collective investment schemes, mainly unit trusts and OEICs. This will reduce the internal cost of these investment schemes. People have welcomed this move. It makes the UK a more attractive location to set up these funds in. There is also the abolition of stamp duty and SDRT on unlisted securities that are admitted to trading on a recognised growth market, such as unlisted shares traded on the alternative investment market (AIM). That is positive. It reduces the cost of dealing in these shares. It could give a boost to the market. It could also mean that it is more attractive to put equity investment into these companies.

Are there any changes in the provisions since the draft bill was published?On the partnership changes, there was quite a bit of extra guidance given and there were some extra provisions put in to facilitate those who have to defer income under the Alternative Investment Fund Managers Directive 2011/61/EU.

Why were these changes made?The changes were intended to be helpful though they do not go far enough. Where a good case could be made that the original proposal had an adverse effect and that this had not been intended, HMRC did make some changes.

Did the changes achieve their purpose?Time will tell. It means that the choice of an LLP or not is less of a tax decision and more of a commercial one.

How does this impact your clients and how will you be advising them?On the partnership changes, businesses will need to take advice on their structure and they will need to consider which partners will continue to have self-employed status. Clients are looking at this and considering whether they wish to change some of the terms to ensure their people still fall within the self-employment rules. Some businesses will also consider whether they want to continue with the LLP or become a limited company. There are still benefits to an LLP. The LLP has extra flexibility which outweighs the tax changes.

Regarding the Code of Practice on Taxation for Banks, banks have to decide whether they want to sign up. For many clients, that may be a relatively straightforward decision - particularly if the banks provide ‘simple’ banking product (eg branches of overseas banks). If a bank wants to sign up, we would advise them to consider the processes, procedures and controls they have in place in order to comply with the requirements placed on them. We would expect most banks would have those systems and controls in place. Boards also need to understand what they are signing up to. They will not want the adverse publicity of being named by HMRC for having breached the code.

On the SDRT and stamp duty changes, we are letting some people know that the UK is open for business.


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Finance Act 2014 - what it means for employment taxes

What are the key employment tax implications for businesses of the Finance Act 2014 (FA 2014)? Emma Bradley and Charlotte Williams of Veale Wasbrough Vizards LLP focus on the three major changes, namely those relating to onshore employment intermediaries, individual members of limited liability partnerships (LLPs) and employee share schemes.

Original newsThe presumption of self-employment for salaried members of LLPs is removed to tackle disguised employment relationships through LLPs. In addition, changes are made to the pay as you earn (PAYE) system to prevent income tax avoidance by onshore employment intermediaries.

What is the significance of FA 2014 receiving Royal Assent for employment lawyers?FA 2014 received Royal Assent on 17 July 2014, having passed through the Committee stage with relatively few amendments being made following its draft publication in December 2013. Although the Autumn Statement 2013, publication of the Bill and the 2014 Budget were all generally considered low-key events by commentators, FA 2014 does introduce some significant changes that affect employment taxes.

As usual, FA 2014 implements various updates to rates, limits and allowances effective from 6 April 2014. However, there have been more substantial changes that have been made in relation to:

• onshore employment intermediaries

• limited liability partnerships (LLPs)

• employee ownership and share schemes

What’s changed in relation to onshore employment intermediaries?The government issued a consultation on ‘false self-employment’ to consult on measures to curb National Insurance Contributions (NIC) and PAYE avoidance schemes involving intermediaries in December 2013. The responses were published on 13 March 2014.

The consultation and proposed changes were in response to HMRC’s growing concern that the use of intermediaries (commonly used in the construction industry) to avoid liability for PAYE and NICs was increasing and expanding to other sectors. The legislation shifts the burden of compliance up the supply chain to rest with the UK agency engaged with the UK end client.

Changes from draft legislationBetween the publication of the draft legislation and receiving Royal Assent, further measures were included which dealt with some of the concerns raised in the consultation. Respondents were concerned that agencies would be held liable for tax and NICs for workers for whom false documentation had been provided (for example, documentation indicating a lack of control or a deduction of tax). In response to this, the legislation was amended to alter who is responsible for the tax liability so it falls with the person or company supplying, rather than receiving, the false information. As such, directors of intermediaries could find themselves personally liable for tax and NICs where false information is supplied to the agency.

Impact on clientsAgencies should urgently review, and consider amendments to, their arrangements and agreements with purported self-employed contractors and/or intermediaries in order to avoid incurring liability for tax, NIC, interest and penalties in the event that HMRC find the worker is, in reality, an employee. Special care needs to be taken to ensure information supplied pertaining to a worker’s status is accurate in terms of reflecting the reality of the situation, rather than just the contractual arrangements.

As ever, HMRC will look at the reality of the relationship, rather than just the contractual basis of it, and will apply what is commonly referred to as the ‘indicia of employment’ to determine whether an employment relationship exists.

Following the consultation, HMRC has produced further guidance on this point and have also clarified the interaction with intermediaries legislation (IR35). The additional guidance offered by HMRC states that supervision can include simply helping the worker, such as helping them develop their skills and knowledge.


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Businesses will have to carefully consider their practices in order to ensure, in so far as possible, that they are not caught out. While guidance is available, businesses are still faced with the unenviable task of proving a negative if liability for tax and NIC is to be avoided.

What’s changed in relation to LLPs?Another area where HMRC has targeted what it perceived to be abuse of self-employed status is that of LLPs. Before the changes were introduced, members of LLPs were presumed to be self-employed and were taxed accordingly. However, changes, effective from 6 April 2014, are likely to give rise to additional tax charges for LLPs by virtue of the fact that certain members are now categorised as salaried members akin to employees for tax purposes rather than partners in the traditional sense where certain conditions are met.

In brief, the conditions relate to ‘disguised salary’, including a measure of contribution/risk and influence over the affairs of the LLP by reference to the ‘disguised salary’.

Changes from draft legislationThe government significantly changed the conditions between the publication of the initial proposals in March 2013 and the publication of the draft legislation. As such, there were calls for the delay of the introduction of the changes (not least from the House of Lords Economic Affairs Committee’s Finance Bill Sub-Committee) to allow the new conditions to be widely consulted on.

Unfortunately, this request was not granted. Commentators generally agree the measures were premature and disproportionate and it does indeed seem very likely that genuine commercial businesses and arrangements will be caught by the new rules.

Impact on clientsWe recommend firms review their capital structure and profit sharing arrangements and look to ensure allocations can be commercially justified.

Additionally, the government has also sought to prevent individuals from taking advantage of the differences in tax rates for companies and individuals. Where partnerships and LLPs have a corporate partner or member, HMRC will seek to reallocate excessive profits from the non-individual corporate entity to the individual partners.

What’s changed in relation to employee ownership and share schemes?In addition to the significant changes made in 2013, FA 2014 also makes some significant changes to employee ownership and share schemes. These changes are a strong indication the government is indeed committed to encouraging increased employee ownership although it will remain to be seen whether these changes have the desired impact.

HMRC approved schemes have been around for some time. Significantly, the changes increase the limits in terms of benefits that may be received, include optional features that allow for greater flexibility and operation with a global outlook and improve the administrative burden by moving to online notification. Companies wishing to take advantage of the changes should take steps to update the scheme rules.

Impact on clientsShare plans, such as share incentive plans, save as you earn schemes and company share option plans no longer need prior approval by HMRC, rather the employer company will need to self-certify and register with HMRC. As such, companies will need to take great care, and potentially seek legal advice, prior to the implementation of such schemes. Although the changes were designed to allow for easier and cheaper implementation of the plans and were generally welcomed for this reason, this increased risk might mean that, in practice, this is not achieved. Existing schemes should issue a notice of conformity.

Companies will also need to ensure they are prepared for the annual online filing requirements that will be mandatory from April 2015.

What are your conclusions of FA 2014?On the whole, we agree with the stance taken by other commentators, namely that this is a low key Finance Act. However, where changes have been made, they have been rushed through taking the ‘sledgehammer to crack a nut’ approach.


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Finance Act 2014 - what it means for pensions taxes

The Finance Act 2014 (FA 2014) can be seen as a precursor to the new defined contribution (DC) pensions regime to be introduced in April 2015. Richard Lee, partner and head of the Combined HR Solution team at Wragge Lawrence Graham & Co, explains the changes made and what to expect in the future.

Original newsFrom 27 March 2014 the minimum income requirement for accessing flexible drawdown will be reduced to £12,000 while the capped drawdown limit will be increased to 150% of an equivalent annuity.

What are the key developments in pensions as a result of the Finance Act receiving Royal Assent?In its March 2014 Budget, the government announced that from April 2015, DC members could have full flexibility over how they use their pension savings. As an interim measure, from 27 March 2014, FA 2014 introduced new small pot, trivial commutation and drawdown limits.

In relation to pensions liberation, from 20 March 2014 there are changes to the registration (or subsequent de-registration) of pension schemes and from 1 September 2014 there is a new requirement for a scheme administrator to be ‘a fit and proper person’.

The FA 2014 also contains transitional protection (known as Individual Protection 2014) for members affected by the new £1.25m standard lifetime allowance for 2014/15.

Are there any changes in the provisions/new provisions since the draft bill was published?Some of the key changes introduced were as follows:

• introducing a temporary extension of the period by which a pension commencement lump sum (PCLS) may precede a pension

• introducing a temporary relaxation to allow transfers of pension rights after a PCLS has been paid - for instance, to other providers to enable short-term drawdown pending the commencement of the new DC pension flexibilities in April 2015

• allowing PCLSs repaid to pension schemes within certain times to be treated as never having been paid, and

• allowing a member who received a PCLS before 27 March 2014 to commute the uncrystallised expected pension to a lump sum under the trivial commutation or small pot rules so long as that further lump sum is paid on or after 6 July 2014, but before 6 April 2015

Why were these changes made?The changes were intended to accommodate HMRC’s updated guidance which was issued in April 2014. This addressed the ‘problem’ of a PCLS being paid more than six months in advance of a pension where a retiree decided to postpone taking an annuity given the budget announcement on DC flexibilities on offer from April 2015, or managed to cancel those that were still the subject of a cooling-off period.

Do you think they achieve their purpose?The new provisions achieved their aim of giving the force of law to the new flexibilities, outlined in HMRC’s April 2014 guidance. However, there is not absolute clarity in relation to members who took their PCLS before 27 March 2014 and the rest of their savings as a further lump sum before 6 July 2014 (where their total pension savings were below the new £30,000 trivial commutation limit).

More generally, FA 2014 is a stepping stone to the new DC pensions regime to be introduced in April 2015. It will need to be read in conjunction with the legislation to be published later in 2014, which will facilitate that new regime.

The provisions dealing with registration (and subsequent de-registration) of pension schemes will, alongside the Pensions Regulator’s Scorpion initiative, hopefully help to stem the tide of pension schemes being used inappropriately as pensions liberation tools.


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Were there any other changes you think should have been made?Nothing in relation to these particular changes, but we still have charge capping, pot follows member and removal of active member discounts to come.

How does this affect your clients?Trustees will need to decide whether they want to take advantage of the new trivial commutation, small pot and drawdown limits which were made available from 27 March 2014. Scheme rules will need to be reviewed to establish whether the changes automatically flow through or whether rule amendments are required. Trustees should consider whether to communicate these changes (and the Budget 2014 changes more generally) to members and, if so, how best to do so.

The pensions liberation developments are welcome. However, trustees who are faced with a member’s transfer request to a suspected pensions liberation scheme are still in a difficult position. The Pensions Ombudsman is currently looking at a number of complaints in relation to transfers to suspected pensions liberation schemes - transfers which have both been blocked and allowed. Those determinations are eagerly awaited.

Finance Act 2014 - what it means for private client lawyers

What are the key implications of the Finance Act 2014 (FA 2014) for private client lawyers? Kate Davies, a solicitor specialising in tax and trusts at Wedlake Bell, examines the significance of the new legislation and what it will mean in practice.

Original news

What are the key developments on private client issues as a result of the Finance Act receiving Royal Assent?The annual charge on high-value residential properties held through corporate envelopes and the capital gains tax regime for disposals of the same properties introduced by the Finance Act 2013 (FA 2013) is being extended. From 6 April 2015 properties worth more than £1m will be caught, and from 6 April 2016 properties worth more than £500,000 will be caught.

There is no such delay with the corresponding measures relating to stamp duty land tax. The rate of 15% which applies to properties being purchased though a corporate envelope now applies to properties with a value of £500,000 or more.

Another development of a concept first introduced in FA 2013 sees borrowed funds disallowed as an inheritance tax deduction where they have been put into a UK foreign currency bank account. This is relevant for non-resident and non-domiciled persons, for whom such accounts are outside the scope of inheritance tax.

A change to private residence relief sees the final period exemption slashed to 18 months. Still more than the 12-month period given when private residence relief was first introduced, but less than the 36 months we have been used to since 1991.

New rules have been introduced to prevent non-domiciled employees from artificially splitting their employment contracts in order to shift income to an offshore contract.

The inheritance tax (IHT) filing and payment dates for relevant property trusts have been aligned and, for the purposes of calculating the IHT due on ten year anniversaries income which arose more than five years ago, will be treated as capital.

Are there any changes since the draft bill was published?The provisions on UK foreign currency bank accounts which are disallowed as an IHT deduction now include a deemed order of discharge if a liability was discharged in part and was used to finance a foreign currency bank account and any other asset.

The dual contract provisions confirm that income which will be taxed on an arising basis will not be subject to pay-as-you-earn (PAYE). An earlier consultation resulted in carve outs for directors owning less than 5%, employments held for legal or regulatory reasons, and a reduction in the comparative tax rate.


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Why were these changes made?The deemed order of discharge was introduced to determine whether the discharged part of the liability is attributed to financing the bank account, with a view to preventing the avoidance of the restrictions on deductions by manipulating debt repayments.

The confirmation of the PAYE treatment of income taxed on an arising basis under the dual contract rules provides certainty in an area that was previously unclear. The other changes limit the scope of the provisions to more accurately target dual contacts used for avoiding tax.

Do you think they achieve their purpose?The deemed order provides for the discharged part of the liability to be attributed to the financing of certain types of property, but the order is reversed depending on the timing of the partial discharges so as to be most favourable for HMRC.

As for the dual contact provisions, there is still a risk that genuine commercial arrangements could be caught.

Were there any other changes you think should have been made or that were dropped?The government decided to continue consulting on the simplification of trust charges rather than include new provisions in FA 2014 as originally planned. This was a welcome decision as some of the proposed measures were argued to go beyond simplification and represented a fundamental change to the regime.

As for the alignment of tax filing and payment dates, the original consultation suggested that the return and payment dates might be aligned with those for the self-assessment cycle but this idea was dropped, missing the opportunity to reduce the compliance burden on trustees.

How does this affect your clients?The widening of the scope of some pre-existing measures has increased the number of clients who are affected by these measures. As for the new measures, clients may find that pre-existing arrangements are now caught.

Trustees need to be aware of the new filing and payment deadlines for trusts to ensure these are not missed.

How will you be advising them? It is important that clients review their position carefully to check that they will not fall foul of the new provisions on dual employment contracts or IHT deductions. Clients also need to check whether they will become subject to the high-value residential property regime to ensure that they review their structures before the new thresholds come into effect and that they comply with the filing and tax obligations for affected properties.

Finance Act 2014 - what does it mean for incentivised investment into social enterprises?

The social investment tax relief (SITR) has been implemented to encourage people to support social enterprises. With similar enterprise schemes already in place, Nathan Williams, partner, and Natalie Stoter, solicitor of TLT LLP, explain how the new relief will benefit the more philanthropic investor.

Original newsA range of income and capital gains tax reliefs are designed to provide investment incentives for individuals in relation to qualifying social enterprises from 6 April 2014. Income tax relief will be available at 30% of the amount invested.

What are the key developments in incentivised investment as a result of the Finance Act receiving Royal Assent?With the Finance Act 2014 (FA 2014) receiving Royal Assent on 17 July 2014, a new tax relief was enacted to facilitate private investment in social enterprises. The introduction of the SITR for investments made from 6 April 2014 follows on from the HMRC consultation carried out last year. SITR is provided for in FA 2014, s 57, schs 11, 12.


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SITR aims to encourage individuals to support social enterprises (effectively, the ‘third sector’) and to assist social enterprises access new sources of finance. The government has suggested the scheme could generate up to £480m over five years for the social enterprises sector and it is also hoped the scheme will help to kick-start and encourage crowdfunding in the long-term for social enterprises.

The SITR provisions share some similarities with the seed enterprise investment scheme (SEIS) and the enterprise investment scheme (EIS) rules.

The carrot - SITR offers the following tax incentives to individual investors:

• income tax relief at 30% of the amount invested (subject to an annual £1m investment limit) - the relief is given by way of a reduction in income tax liability for the tax year in which the investment is made

• capital gains tax (CGT) deferral where gains are reinvested in SITR qualifying investments

• no CGT on any gain arising on the disposal of the SITR investment itself

• The stick - SITR conditions and limits:

• individuals must invest in qualifying shares or unsecured, subordinated debt issued by a social enterprise (such as a charity, community interest company (CIC), community benefit society (Bencom) or an accredited social impact contractor) - the investment must be fully paid up

• the investor must own the investment for at least three years, cannot own more than 30% of the social enterprise and cannot be an employee or paid director - there is currently a £1m annual investment limit

• the social enterprise must have fewer than 500 employees, gross assets of no more than £15m and must carry on a qualifying trade (community renewable energy projects benefiting from feed-in tariffs (FITs) will not qualify for example)

• the tax relief will be clawed back if there are disqualifying events within the three year investment period

• for EU state aid purposes, the maximum amount that can be invested per eligible social enterprise is EUR 344,827 (about £275,000) over three years

Are there any changes in the provisions since the draft Bill was published? The primary change in provisions since the publication of the draft Bill was the inclusion of accredited social impact contractors to the definition of social enterprise. In the draft Bill, the definition of social enterprise was restricted to CICs, Bencoms or charities. There were also various technical points to coincide with this inclusion, in order to avoid any abuse of SITR.

Accredited social impact contractors is defined in the legislation as a company limited by shares that is accredited as a social impact contractor. There are three conditions for accreditation:

• the Minister must be satisfied the company has entered into a social impact contract (also referred to as a social impact bond contract (SIBs))

• the company must be, and must at all times since incorporation have remained, established for the purpose of entering into and carrying out the terms of such a contract

• the activities of the company in carrying out the SIBs will not consist wholly or as to a substantial part in excluded activities

SIB contractors are often engaged by external organisations to help improve their social impact and to effectively sub-contract specific services - a homeless charity for example will be engaged to place a specific number of individuals into accommodation.

Why were these changes made? There was a fear that the original proposal to restrict the SITR to just charities, CICs and Bencoms would exclude existing social organisations, which were companies limited by shares but which did not fall within one of the other categories.

During the course of the Bill, it was amended to allow accredited SIB contractors (companies limited by shares) to be included within the definition of social enterprises.

This was the first step by the government to allow the scheme to expand, which has prompted further plans for expansion, as detailed further below.

Do you think they achieve their purpose? As the SITR has only been available since April 2014, it is too early to comment on whether this incentive has achieved its purpose. Therefore, it remains to be seen just how extensively the scheme is picked up by eligible investors and by social enterprises seeking to raise funds.


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However, it is telling that HMRC is already consulting on the expansion of the SITR scheme by publishing a consultation document in advance of the Bill receiving Royal Assent. SITR, as set out in FA 2014, is possibly just the starting point.

Were there any other changes you think should have been made?One of the main hurdles to take up of SITR will be the state aid de minimis level set at EUR 344,827, especially for the larger enterprises seeking to raise significant amounts of tax incentivised funding.

The latest consultation document seeks to gather evidence of any actual or perceived funding gap to build a case for extending this limit (possibly to £5m in line with current EIS limits).

There are also proposals to extend SITR to include an indirect investment option, either altering the existing Venture Capital Trust (VCT) rules or adopting a social enterprise tailored VCT-like system. Another proposal is to look at extending the scope of qualifying accredited SIB contractors under SITR so that a wider range of social enterprise outsourcing contractors would be eligible for SITR.

Clearly, the government feels the initial purpose in introducing this tax relief has not been fulfilled and there is still further potential in SITR.

How does this impact your clients? We regularly advise clients on EIS and SEIS investment arrangements and adding an additional tax efficient investment option will be welcomed, especially by those of a more philanthropic nature.

As SITR develops and potentially expands to include a wider range of accredited contractors, public sector clients and those private sector clients who work closely with the public sector may now take a closer interest in the make-up of social enterprises that may be involved, at whatever stage, in the delivery of services at the local/community level to ensure maximum fund raising opportunities for the social enterprise.

Following the exclusion of companies (but not CICs etc) benefitting from renewable obligation certificates (ROCs) and renewable heat incentives (RHIs) from the EIS, SEIS and VCT regimes (as enacted in FA 2014 in respect of shares issued or investments made on or after 17 July 2014), it will be interesting to see if an expanded SITR could possibly develop to fill some of the gaps left by the removal of such tax reliefs for investment in renewable energy projects.

Finance Act 2014 - what it means for real estate lawyers

Simon Yeo and Matthew Roach, senior tax managers at KPMG, consider how the changes introduced by the Finance Act 2014 (FA 2014) will affect the real estate industry, with a focus on real estate funds.

Original newsFA 2014 received Royal Assent on 17 July 2014. In addition to other measures announced at Budget 2014 and Autumn Statement 2013 being implemented, part of the stamp duty reserve tax (SDRT) regime applicable to unit trusts and open-ended investment companies is abolished.

What are the key aspects of FA 2014 that affect the real estate funds industry?One of the long running concerns of the UK funds industry has been that where a UK manager manages an offshore fund, that fund could become UK tax resident due to the activities of the manager. There is currently an exemption for funds which are undertakings for collective investment in transferable securities (UCITS) and domiciled outside the UK that allows them to be managed by UK management companies under the UCITS IV Directive 2009/65/EC. However, the previous law did not extend to other types of offshore funds. FA 2014 introduced measures to extend the existing exemption to include all non-UK alternative investment funds (AIFs). Importantly, by extending the definition to non-UK AIFs, this will now cover closed-end vehicles, and includes Jersey and Guernsey domiciled property funds. This change potentially allows the boards of Channel Islands resident property funds that hold UK property to meet in the UK without the fund becoming UK tax resident. This is sure to be welcomed by directors wishing to avoid the commute to offshore board meetings.


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However, the abolition of SDRT on almost all transactions in units in UK unit trust schemes may encourage more property unit trusts to be established in the UK rather than in Jersey and other offshore jurisdictions.

At an institutional level, one of the key changes from FA 2014 has been the amendment of the definition of ‘institutional investor’ to include real estate investment trusts (REITs) and their foreign equivalents. REITs have historically not been able to attract significant capital from other REITs due to a restriction that prevents them from being close companies for UK tax purposes. HMRC have been encouraged to make changes to the legislation to enable REITS to invest in other REITS for commercial reasons such as removing barriers to further future investment activity and facilitating easier access to joint venture financing opportunities. These changes have been introduced in FA 2014 and will now allow REITs to take larger stakes in other REITs and potentially set up corporate joint ventures as sub-REITs.

FA 2014 gave effect to new powers for HMRC to issue ‘follower notices’ to force taxpayers to amend their tax returns to take account of relevant judicial decisions, or face a penalty. In addition an ‘accelerated payment notice’ can be issued to require tax to be paid in advance of the conclusion of an enquiry where (among other things) a follower notice has been issued or where the scheme was disclosable under the disclosure of tax avoidance schemes regime. These new rules are not restricted to the real estate industry, but one target is some of the stamp duty land tax (SDLT) planning arrangements real estate buyers have been using. They can no longer expect to be able to hold on to their money while they dispute their tax position with HMRC.

What changes were made to the SDLT and annual tax on enveloped dwellings (ATED) regimes and why?FA 2014 brought in some SDLT changes for charities and collective enfranchisement transactions but the more notable changes to the ATED and SDLT regimes were adjustments to the thresholds for ATED and the 15% SDLT charge.

Any residential property now purchased for over £500,000 is within the 15% SDLT regime if purchased by a corporate or other envelope with no legitimate property business. Similarly, ATED will apply to properties worth more than £1m from 1 April 2015 (£2m is the current threshold) and, from 1 April 2016, ATED will apply to properties worth over £500,000.

The reason for the rate change is probably that it was not realised that lower value properties were being enveloped or that any significant tax income would be raised from the taxes - they were intended to act as a deterrent to enveloping and incentive to de-envelope, rather than to raise revenue. In the autumn, HMRC was expecting to raise five times the forecasted £20m ATED revenues for 2013/14 and, logically, it can be no more objectionable to envelope £2m+ dwellings than to envelope cheaper homes.

What changes were expected or hoped for but did not materialise? It had been hoped that a seeding relief would be introduced for certain property funds, including Property Authorised Investment Funds (PAIFs) and Authorised Contractual Schemes (ACSs) to facilitate the growth of these vehicles. However, these proposals were delayed and instead an industry consultation has been launched. The consultation proposes that a seeding relief will be introduced on the initial introduction of portfolios into PAIFs. This is likely to have a number of qualifying conditions and be subject to a clawback of the SDLT that would otherwise have arisen where the seeder sells down their interest in the fund within a three-year period.

For ACSs the main proposal is to introduce a new exemption from SDLT for transactions in units in an ACS and make the scheme manager responsible for the tax, as well as introducing a seeding relief for ACSs fulfilling certain criteria. The consultation runs until 12 September 2014. If the proposals are introduced with sensible safeguards this could be a significant opportunity for the PAIF market to grow further and the ACS to be a viable property fund model.

What are the practical implications of the changes that advisers need to note?One point to note in respect of UK board meetings of Channel Island property funds is that these may create inadvertent VAT concerns if a fixed establishment is created in the UK.

In respect of the ATED rate changes, the practical problem for taxpayers will be the increased ATED-compliance burden where residential property is held in companies or other envelopes for business purposes - there is no more ATED to pay as a result of the changes to the bands (because the reliefs for genuine business use should apply), but there will be increased annual filing obligations to claim the relief. However, HMRC is currently being pressed to relax the ATED compliance regime and there may be a positive outcome here.


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What effect have the changes had on transactions and the market?It is too early to tell whether the changes to the REIT rules will make a significant impact, but we expect this will create new opportunities for REITs to co-invest with each other on significant transactions, as well as provide M&A opportunities within the sector.

The stamp taxes changes have not led to any major market changes as the majority of normal commercial transactions are not significantly affected by the changes. However, the follower notice and accelerated payment regime has brought an end to taxpayers undertaking SDLT schemes on the basis that the unpaid SDLT was cheap funding for the protracted period these schemes were typically disputed before the tax was eventually paid.

Finance Act 2014 - what it means for environment lawyers

Alex Ibrahim, of the Nabarro environment group, considers the likely implications of the new legislation on landfill tax rates, climate change levies and new regimes for oil and gas activities.

Original newsThe Finance Act 2014 (FA 2014) received Royal Assent on 17 July 2014. The environmental and energy aspects are spread across several sections, particularly in Part 2 where the aggregates levy and climate change levy (CCL) changes are detailed.

What are the key developments in the environmental sector as a result of FA 2014 receiving Royal Assent?The key developments as a result of FA 2014 in this sector were predominantly energy-related. These included:

• the setting of the main rates of the CCL for 2015/16, which have been adjusted in line with the Retail Price Index (RPI), as announced in the 2014 Budget

• the setting of the carbon price support (CPS) rates for the CCL for coal and other solid fossil fuels for 2014/15 and 2015/16

• the provision of a cap on the CPS rates of CCL with effect from 1 April 2016• the introduction of a CCL exemption for metallurgical and mineralogical processes from 1 April 2014• the suspension of certain exemptions from the aggregates levy, from 1 April 2014, pending EU state aid investigation• empowering the Treasury to extend, by order, some enhanced capital allowances (ECAs), including for cars with low

carbon dioxide emissions, gas refuelling equipment and zero emission goods vehicles

However, FA 2014 also amended the standard and lower rates of landfill tax for 2015/16. These have been adjusted in line with the RPI, as announced in the 2014 Budget. The standard rate of landfill tax has increased from £72 per tonne to £80 per tonne as of 1 April 2014.

FA 2014 also introduced a new tax regime in connection with onshore conventional and unconventional oil and gas activities (which would include hydraulic fracturing). This included extending the ring fence expenditure supplement (RFES) and a new onshore allowance (forms of tax relief for specific exploration and production activities).

How does this impact your clients and how will you be advising them?Focusing on the environmental (as opposed to the energy-related) aspects of the above, we will be making clients aware of the new rates of landfill tax, as appropriate. This will be of particular relevance to those clients whose activities involve the redevelopment (and, where necessary, the remediation) of brownfield land.

We will also be closely following the development and impact of the new tax regime for onshore conventional and unconventional oil and gas activities with interest. While the basic outline is described in FA 2014, the new regime will be developed in secondary legislation. Where relevant, we will be factoring this new regime into the advice we provide to our clients.


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Finance Act 2014 - tackling tax avoidance and evasion?

How will the Finance Act 2014 tackle tax avoidance and evasion? Catherine Robins, partner at Pinsent Masons, explains the new powers and advises that the accelerated payment notice (APN) and follower notice provisions will certainly act as a significant incentive to anyone who has taken part in a mass marketed avoidance scheme to give up the fight and simply settle their dispute.

What are the key developments in tax avoidance and evasion as a result of the Finance Act 2014 (FA 2014) receiving Royal Assent?This year’s Finance Act introduced controversial new powers designed to deal with HMRC’s backlog of cases involving tax avoidance schemes. HMRC can now issue APNs to force avoidance scheme users to pay the disputed tax up front, rather than being able to wait until HMRC wins a case against them in the tax tribunal, removing the cashflow advantage that previously existed in direct tax cases. FA 2014 also gives HMRC the power to issue a ‘follower notice’ if it wins a case against a taxpayer that HMRC considers is relevant to another taxpayer’s case, forcing that other taxpayer to settle their case or face a possible 50% penalty if they are ultimately unsuccessful.

In a measure to clampdown on sellers of aggressive tax avoidance schemes, HMRC will be able to issue a ‘conduct notice’ (the tax equivalent of football’s yellow card) to promoters who have breached ‘threshold conditions’, allowing HMRC to impose behavioural conditions on the promoter. A breach of these conditions will allow HMRC to issue a ‘monitoring notice’ if a tribunal judge agrees. Monitored promoters will be obliged to notify their clients that they fall into this category and additional obligations fall on intermediaries and clients - all designed to deter clients from dealing with the promoters in question and effectively to put the promoters out of business.

Are there any changes in the provisions - or new provisions - since the draft bill was published?When the Finance Bill proposals were announced in the Autumn Statement in December last year the APN provisions were only to apply if HMRC had issued a follower notice. However, a consultation document issued in January proposed that HMRC should also have the power to issue APNs where a scheme has been disclosed under the disclosure of tax avoidance scheme (DOTAS) rules or a general anti-abuse rule (GAAR) counteraction notice has been given.

The extension of APNs to DOTAS schemes is controversial because it applies to schemes disclosed under DOTAS before the APN changes became law. It therefore has an element of retrospection and has ‘moved the goalposts’ for those who may have entered into schemes up to 10 years ago, when the public perception of tax avoidance was very different.

The high risk promoter rules were changed from the draft bill, so that the First-tier Tribunal has to approve a monitoring notice before it can be issued. On the original proposals there was simply a right of appeal against the notice to the tribunal.

Why were these changes made?The changes to APNs were made so that the provisions would be more effective in removing the cashflow advantage to the taxpayer in DOTAS schemes, which make up the majority of cases in HMRC’s backlog. HMRC is hoping that faced with the prospect of having to pay the tax, many will simply give up the fight and settle their dispute. HMRC has published a list of some 1,200 DOTAS schemes where it intends to issue APNs over the 20 months from August 2014 to around 43,000 taxpayers.

Do you think they achieve their purpose?The APN and follower notice provisions have been described as ‘game changing’ and will certainly act as a significant incentive to anyone who has taken part in a mass marketed avoidance scheme to give up the fight and simply settle their dispute. For future schemes, HMRC hopes that the changes will be a deterrent to taxpayers entering into schemes in the future. However, the market has changed significantly and the change in the public’s perception of tax avoidance and the media’s naming of participants in schemes may be an equally powerful deterrent.

However, many have criticised the retrospective nature of the provisions and they may be susceptible to judicial review challenges. HMRC has stated openly that it expects that there will be more litigation as a result of the changes. Litigation could arise from judicial review challenges to the notices or taxpayers wanting to push on with their cases in the tribunal. Once taxpayers have had to pay the tax and/or have the threat of follower notice penalties hanging over them, there is no longer an incentive to drag out a dispute with HMRC. Rather the incentive is to press on with your case as quickly as possible in the hope of recovering any tax you have paid under an APN.

The high risk promoter provisions probably come too late to make a significant impact, as the market for aggressive tax avoidance schemes is now very small, due to the media outcry over tax avoidance.


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How does this impact your clients? And how will you be advising clients?Anyone whose scheme is on the list of DOTAS schemes where HMRC has said that it will be issuing APNs will need to start thinking now about how they will fund the tax if they receive a notice. If a scheme is on the list a notice won’t necessarily be issued immediately, HMRC has said that it will issue the notices over a 20-month period, beginning in August.

If a notice is issued the taxpayer has 90 days to pay the tax, unless they make representations that the notice should not have been issued to them which, depending on the timing, could give them a further 30 days to pay the tax. So, depending upon when the notice is issued, a taxpayer may have a few months or nearly two years to come up with the cash.

Anyone who has entered into a mass marketed scheme needs to be taking advice - independent of the promoters of the scheme - about what they should do next. This advice could include ensuring that HMRC is entitled to issue a notice to them, seeing whether the notice could be challenged and taking a second opinion on the likelihood of the scheme succeeding in the courts.

Are any changes required in drafting documents?APNs and follower notices can apply to companies as well as individuals so this may be another area to cover in tax warranties on company acquisitions.

What happens next?This is not the end of the story - the APN and follower notice provisions do not currently apply to national insurance contributions (NICs). However, the National Insurance Contributions Bill, which is currently going through Parliament, will extend them to NICs. This is potentially controversial if HMRC tries to use them against employee benefit trust (EBT) and employer financed retirement benefit (EFRBS) schemes, given its recent loss in the Rangers case (Murray Group Holdings Ltd v Revenue and Customs Comrs [2014] UKUT 292 (TCC), [2014] All ER (D) 109 (Jul)).

Also controversial changes enabling HMRC to take tax debts direct from a debtor’s bank account are still in the pipeline. A consultation exercise finished on 29 July 2014 so these provisions may be introduced next year - giving HMRC potentially even greater powers.

Catherine Robins is the tax team’s technical partner, providing technical assistance to clients and members of the team on all areas of corporate tax including corporate finance and M&A work, private equity, employment tax and property tax. She is also a member of the income tax sub-committee of the Law Society Tax Law Committee.

Finance Act 2014 - tackling tax administration

How will the Finance Act 2014 tackle tax administration? Keith Gordon, a barrister at Atlas Tax Chambers, and member of the LexisPSL Tax consulting editorial board, explains the key changes and considers whether or not they will achieve their objective.

What is the key development in tax administration as a result of the Finance Act 2014 receiving Royal Assent?The most important development is HMRC’s ability to issue accelerated payment notices (APNs) and follower notices to taxpayers in what might loosely be considered as tax avoidance cases. The two have different effects and can be issued in different circumstances (summarised below).

The underlying logic of these steps was that HMRC felt that they (and the tribunals) were overwhelmed by the number of tax avoidance cases that were awaiting resolution. Not only were these cases tying up administrative resources at HMRC, but in the absence of a final determination of the case by the tribunal, taxpayers were not paying the tax at stake.

This state of affairs was particularly unattractive to HMRC in cases where they considered there was already a decision of the tribunal (or the higher courts) which showed that the avoidance scheme was ineffective.

Follower noticesIn cases where there is some decision in a related case (any connection to the subject matter and reasoning would be sufficient), HMRC can now issue a follower notice. Such a notice gives the taxpayer an ultimatum - either give in (and adopt the earlier decision of the courts/tribunal) or pay a 50% penalty for having the audacity to consider that the taxpayer’s


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case might be decided differently. A follower notice can be issued even if the earlier decision is one of the First-tier Tribunal, whose decisions are not otherwise binding authority.

APNsIn cases where a follower notice has been given, HMRC may also issue an APN.

APNs may also be issued in cases involving notifiable arrangements for the purposes of disclosure of tax avoidance schemes (DOTAS) or in cases where the general anti-abuse rule (GAAR) is being invoked and at least two members of the GAAR panel consider the taxpayer to have undertaken abusive planning.

An APN is effectively a demand for the tax in dispute ahead of the tribunal’s resolution of the particular case.

Should the taxpayer decide not to (or cannot) pay the tax up front then (in addition to any statutory interest) the taxpayer will be liable to penalties of up to 15% of the tax at stake.

Are there any changes in the provisions since the draft Bill was published?Although some changes were made to the legislation during the Parliamentary stage, those changes are not particularly significant.

Do you think these new rules achieve their purpose?It depends on what their true purpose is and how HMRC apply their new powers.

If HMRC limit the issue of follower notices and APNs to those cases where it is quite clear that the taxpayer’s appeal (or claim, if it has not yet reached the stage of appeal) is bound to fail, then one can understand HMRC’s temptation to cut to the chase and avoid further delays in the resolution of any particular appeal.

However, it should be remembered that these powers are effectively a means for HMRC to secure the result that they want without the supervision of the judiciary. This is constitutionally worrying and therefore the exercise of HMRC’s new powers should be carefully considered.

In particular, there is a real risk that HMRC will use these new powers in wholly inappropriate situations. For example, although there might be a case which HMRC consider to be a relevant judicial authority, a taxpayer could well have good reasons for considering that his/her case would give rise to a different result. The facts might be subtly different. Or the arguments to be put forward might differ. Or the taxpayer might consider that the original decision was just wrong (and it is just unfortunate that the taxpayer in the earlier case was unable to persuade the judge and has not got the stamina to appeal against the decision to the Upper Tribunal). Alternatively, the taxpayer might have a procedural defence (such as the non-fulfilment of the conditions for a discovery assessment) which would trump the fact that the tax was in fact underpaid in the first place.

In such cases, it would be appropriate for the taxpayer to consider challenging HMRC’s use of their new powers. The only real way to do so is by way of judicial review.

Were there any other changes that you think should have been made or which were dropped?Personally, I think that the new rules should not have been introduced as they risk eroding the constitutional checks and balances provided by the separation of powers. Indeed, in many of these cases, HMRC could achieve the desired result by making an application under the Taxes Management Act 1970, s 55(4) for a reconsideration of any previous postponement agreement, particularly if there is a relevant judicial authority that suggests that tax will prove to be payable.

Furthermore, it would have been helpful if HMRC had positively made clear that they do not propose to use their new powers in those cases where the earlier judicial authority is not particularly persuasive or relevant. However, despite being given plenty of opportunity to reassure the tax profession that their exercise of the powers would be that much more focused, HMRC have failed to do so.

How does this impact your clients?The new rules are extremely dangerous indeed. Suppose a taxpayer receives a follower notice and decides that there are good grounds to maintain the appeal. That appeal might well prove to be successful. However, the mere fact that the follower notice was issued (assuming on the review stage that it is upheld) means that the taxpayer risks a 50% penalty merely for the right to appeal to an independent tribunal.


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What makes the rules particularly unconstitutional is that, unless the taxpayer is able to expedite any judicial review process, they effectively require a taxpayer to make a decision as to how to act with an effective guillotine hanging over the taxpayer’s head.

How will you be advising clients?Any taxpayer who has received an APN or follower notice should take immediate legal advice. Although there is a 90-day period for representations, it will be strongly advisable to consider the various options much earlier than that. In fact, even if a taxpayer merely suspects that a notice might be issued, it will still be appropriate for some preliminary advice to be sought so as to avoid the risk of delays should a notice be issued in due course.

Any final observations?As these provisions were going through Parliament, HMRC was separately consulting on proposed powers to collect tax from taxpayers’ bank accounts without judicial oversight.

There is a theme developing and it is worrying. HMRC seem to be keen to avoid judicial supervision of their activities and are trying to devise new statutory ways to obtain taxpayers’ money without the risk of judges intervening.

Keith Gordon practised as a chartered accountant and chartered tax adviser before qualifying as a barrister. He advises in all tax-related matters, extending to social security contributions and benefits. He also has a general chancery practice with a particular interest in probate disputes and partnership disputes. Keith also acts in professional negligence matters, for both claimants and defendants.


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Finance Act 2014 Lexis®PSL Tax Analysis

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