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Tax Bulletin Issue 78

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HM Revenue and Customs -Tax Authorities

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October 2005

Contents

Trusts Modernisation

In his 2003 Pre-Budget Report, the Chancellor announced plans to modernise and simplify the income tax and capital gains tax system for trusts. A consultation document was published on 13 August 2004 and the feedback on 16 March 2005. These documents can be found on the HMRC website at Modernising the Tax System for Trusts.

Budget 2005 introduced two new measures:

  • a standard rate band for all trusts that pay tax at the rate applicable to trusts, and
  • a favourable regime for certain trusts with vulnerable beneficiaries.

At the same time a further discussion document was issued on the detail of other proposals, which have been supported in principle during consultation. These include:

  • income streaming for trustees,
  • harmonised definitions and residence tests for trusts, and
  • sub-funds elections.

These modernisation proposals are for family/personal types of trust, not unit trusts, Venture Capital Trusts or other specialised vehicles that, whilst called trusts, have their own separate taxing system or are taxed as corporations.

Standard rate band

Finance Act 2005 introduces a new section 686D ICTA 1988 which applies to trustees, including non-resident trustees, who are chargeable to United Kingdom income tax at the special trust rates. These special trust rates are the rate applicable to trusts (40%) and dividend trust rate (32.5%). From April 2005 the first £500 slice of trustees’ income, which would otherwise be chargeable at the special trusts rates, is not chargeable at those special trust rates but is instead chargeable at basic (22%), lower (20%) or dividend ordinary rate (10%), depending on the nature of the income.

This new provision applies to the first £500 taxable income that would otherwise be chargeable at the special trust rates. Any income that is already chargeable at the basic, lower or dividend ordinary rates is not included in this £500 band. And, in the case of a non-resident trust, income that arises outside the United Kingdom is also not included in this £500 band.

Section 686D does not apply to chargeable gains – they remain chargeable at 40%.

Order of income

The £500 band applies to the lowest slice of income. The order in which it is applied against income follows the normal income tax rules within s1A ICTA 1988, which provide that dividend income (chargeable at 10%) is the highest slice of income, followed by other savings income (chargeable at 20%) and finally income from a trade or from property (chargeable at 22%).

Therefore the £500 band is set firstly against income that is chargeable at the basic rate. Any amount of the £500 band that remains is then applied to income chargeable at the lower rate. Finally any amount still remaining is applied to income chargeable at the dividend ordinary rate.

Example 1

The trustees of a discretionary trust chargeable at the special trust rates have rental income of £200, receive interest of £160 (after tax of £40 has been deducted at source) and UK dividends of £180 (carrying a non-payable tax credit of £20).

- Non-savings income Savings income Dividend type income Total
Income
£200
£200
£200
-
Tax rate
22%
20%
10%
-
Tax chargeable
£44
£40
£20
£104
Income liable at special rates
£200
£200
£200
-
Apply s686D
(£200)
(£200)
(£100)
-
Income liable at special rates
0
0
£100
-
Tax rate
-
-
32.5%
-
Tax chargeable
-
-
£32.50
-
Less charged at basic rates
-
-
(£10)
-
Tax due
-
-
£22.50
£22.50
Total
-
-
-
£126.50
Less repayable tax suffered
-
£40
-
(£40)
Less non-payable tax credit
-
-
£20
(£20)
Tax due
-
-
-
£66.50

The £500 band is first applied against the rental income of £200, then against the savings income of £200. This leaves £100 of the band remaining, which is set against the dividend income. As a result only £100 of the gross dividend income is subject to the special trust rate.

Net income

The amount of £500 refers to net income that would otherwise be chargeable to the special trust rates and therefore after allowable charges and expenses of management. If in example 1 above the trustees had allowable trust management expenses of £45, in accordance with the order of set off of such expenses, they would be utilised in full against the dividend income. The grossed up amount would be £50 (45 x 100/90) and the tax due would therefore be as follows:

Example 2

- Non-savings income Savings income Dividend type income Total
Income
£200
£200
£200
-
Tax rate
22%
20%
10%
-
Tax chargeable
£44
£40
£20
£104
Income liable at special rates
£200
£200
£200
-
Less gross TMEs
-
-
(£50)
-
Apply s686D
(£200)
(£200)
(£100)
-
Income liable at special rates
0
0
£50
-
Tax rate
-
-
32.5%
-
Tax chargeable
-
-
£16.25
-
Less charged at basic rates
-
-
(£5)
-
Tax due
-
-
£11.25
£11.25
Total
-
-
-
£115.25
Less repayable tax suffered
-
£40
-
(£40)
Less non-payable tax credit
-
-
£20
(£20)
Tax due
-
-
-
£55.25

In this case only £50 of the net dividend income remains chargeable at the special trust rate.

Deemed income

There are various sums that are capital in trust law but are deemed to be income for tax purposes. The standard rate band applies equally to such deemed income. So, for example, profits or gains from the disposal of interests in certain offshore funds, certain deemed income receipts of trustees of employee share ownership trusts and guaranteed returns on disposals of futures or options would, for the purposes of s686D, be taxed at the basic rate.

Receipts under the Accrued Income Scheme, profits from deep discounted securities and gains from contracts for life insurance would, for the purposes of s686D, be taxed at the lower rate. And stock dividends from UK companies and distributions arising from a company’s purchase of its own shares would similarly be chargeable at the dividend ordinary rate.

If the trustees in example 1 above had a gain on a UK life insurance policy, on which tax of £20 is treated as paid, the tax due would be as follows:

Example 3

- Non-savings income Savings income Dividend type income Deemed income Total
Income
£200
£200
£200
£100
-
Tax rate
22%
20%
10%
40%
-
Tax chargeable
£44
£40
£20
£40
£144
Income liable at special rates
£200
£200
£200
-
-
Apply s686D
(£200)
(£200)
-
(£100)
-
Resulting adjustment in terms of tax
-
-
-
(£20)
(£20)
Income liable at special rates
0
0
£200
-
-
Tax rate
-
-
32.5%
-
-
Tax chargeable
-
-
£65
-
-
Less charged at basic rates
-
-
(£20)
-
-
Tax due
-
-
£45
-
£45
Total
-
-
-
-
£169
Less repayable tax suffered
-
£40
-
-
(£40)
Less non-payable tax credit
-
£20
£20
(£40)
(£20)
Tax due
-
-
-
-
£89

(Please note: non-resident trustees are not taxable on gains on a UK life insurance policy.)

The £500 band in this case is applied against the rental income, then the savings income and finally against the deemed income. For this reason, the deemed income is chargeable at 20% rather than 40% as normal. This leaves the dividend income chargeable at the special trust rate.

The tax pool – discretionary distributions

There is a new sub clause to section 687(3) ICTA 1988 to ensure that tax charged at the basic or lower rate (but not at the dividend ordinary rate) will be included in the tax pool. This is relevant where trustees make discretionary distributions to beneficiaries.

Income distributed to a beneficiary by UK resident trustees of a discretionary or accumulation trust is treated as an amount from which tax payable at the rate applicable to trusts (40%) has been deducted. Trustees have to ensure that they have paid sufficient income tax to cover the amount of that deemed deduction, which is available as a tax credit to the beneficiary. Income tax paid by the trustees at the rate applicable to trusts or dividend trust rate (less the 10% non-payable tax credit) goes into what is called the ‘tax pool’. This tax pool can be used to cover the amount of the deemed deduction but trustees must pay additional tax to cover any shortfall. Income tax charged at basic or lower rates usually cannot be used to cover the deemed deduction. However, tax charged at the basic or lower rate (but not at the dividend ordinary rate) under s686D does enter the tax pool and so can be used to cover the amount of the deemed deduction.

If the trustees in example 1 made a discretionary payment of £60 to a beneficiary, the tax due (the deemed deduction) would be £40 (60 x 40/60). The tax pool available, assuming there was no tax pool brought forward from the previous year, equals the tax charged at basic rate on the rental income (£44), at the lower rate on the savings income (£40) and at the special rate on the dividend income (£22.50). The tax pool is therefore £106.50 and sufficient to cover the tax of £40 due on the discretionary distribution, so avoiding any additional charge on the trustees. The amount available to carry forward to the following year is £66.50.

In such a case, tax is paid at basic and lower rate on account of s686D and this is why it is included in the tax pool. Tax paid at these rates for any other reason would not qualify for inclusion.

No need for returns every year

Trustees whose income does not exceed £500 and whose liability is covered in full by tax deducted at source or non-payable tax credits may no longer need to make a return every year. This will mostly affect those trustees whose income is within the £500 limit and is made up of net interest and UK dividends, as they will have no additional liability.

Where HMRC identifies appropriate cases, we shall issue a standard letter to the named trustee, advising that a notice to file a return will no longer be issued every year. This process has already begun though it may take some time to complete. Generally speaking, trustees will be required to make returns at least once every five years.

The letter also makes clear the circumstances in which a return will be required. These are:

  • Where a notice to make a return for a given year is issued.
  • Where no such notice has been given but the trustees’ taxable income for a given year exceeds £500, or
  • their tax liability on the income is not fully covered by tax deducted at source or by a non-payable tax credit and so they have further tax to pay, or
  • they have income, the details of which need to be included in supplementary pages to the return, or
  • they have a capital gain or loss that should be included in a return, or
  • they make a discretionary payment to a beneficiary and the tax pool is insufficient to cover the charge to tax.

Vulnerable beneficiaries

Finance Act 2005 has also introduced a more favourable regime for certain trusts with vulnerable beneficiaries. The broad aim of the special tax treatment is to ensure that the amount of tax charged on income and gains arising to the trustees is no more than it would have been had the income and gains arisen directly to the vulnerable person. It has effect from 6 April 2004.

A Guidance Note has been published on the HMRC website, which provides details of the new regime and explains how to make elections and claims. It can be found at An introduction to the new special tax treatment for certain trusts with vulnerable beneficiaries.

Company Cars - Advisory Fuel Rates for Company Cars

Use of advisory fuel rates

The advisory fuel rates (guidelines on fuel only mileage rates for company cars) were first published in January 2002. It has been possible to use them since then to negotiate dispensations for mileage payments for business travel in company cars.

They are intended to reflect actual average fuel costs at the time they are set. The aim is to save time for both employers and the HM Revenue & Customs by setting out some figures that can be used in the majority of cases. They give employers more certainty about what the mileage rates that they choose to apply mean for tax and National Insurance contributions (NICs).

The rates only apply where employers:

  • reimburse employees for business travel in their company cars, or
  • require employees to repay the cost of fuel used for private travel.

The rates do not apply in any other circumstances. In particular, employees driving company cars are not entitled to use them to claim a deduction if employers reimburse them at lower rates. Such claims should continue to be based on actual costs incurred.

Employers reimbursing employees for the cost of fuel used for business travel

If the rate paid per mile of business travel is no higher than the advisory rate for the particular engine size and fuel type of the car, we will accept that there is no taxable profit and no Class 1 NICs liability. This reflects the fact that they are intended to reflect actual average fuel costs.

We are not suggesting that employers should always use these rates for reimbursing employees for business travel in company cars. The advisory rates represent average fuel costs, and employers may wish to set rates which better reflect their particular circumstances. For example, where the cars in the fleet are fuel efficient, employers may prefer to reimburse at lower rates than those outlined here.

The advisory rates will not be binding where an employer can demonstrate that the cost of business travel in company cars in the fleet concerned is higher than the guideline mileage rates - perhaps where employees need to use particular types of car such as 4x4s to cover rough terrain.

If an employer pays mileage rates that are higher than the advisory rates but is unable to demonstrate that the fuel cost per mile is indeed higher, there is no fuel benefit charge if the mileage payments are made solely for miles of business travel. Instead, any excess will be treated as a taxable profit and as earnings for Class 1 NICs purposes.

Employers who require employees to repay the cost of fuel used for private travel

Providing that all of the miles of private travel have been properly identified, we will accept that there is no fuel benefit charge, and therefore no Class 1A NICs liability, where the employer uses the appropriate rate from the table below (or any higher rate) to work out the cost of fuel used for private travel that the employee must repay to the employer. Again, this reflects the fact that they are intended to reflect actual average fuel costs.

Even if it seems that the actual cost of the fuel could be more than the current advisory fuel rate, it is only in exceptional cases that we will consider arguing that a higher repayment rate should apply. For example, where the employee drives a very large-engined company car that achieves fewer than 16 or 17 miles to the gallon. But we will always accept that the guideline rates can be used to calculate the amount that the employee must make good where the engine size is 3 litres or less.

The advisory rates will not be binding where an employer can demonstrate that employees cover the full cost of private fuel by repaying at a lower rate per mile.

Dispensations not drawn in terms of the advisory fuel rates

Many dispensations contain rates at which employers are entitled to reimburse employees for fuel which the employee has purchased for business mileage in a company car (including a pool car) without any tax or NICs implications. Some of these dispensations quote specified rates per mile, others refer to the advisory fuel rates.

From 1 July 2005, HMRC will interpret all such dispensations (but not any in relation to vans, to which the advisory fuel rates do not apply) as though they referred to the advisory fuel rates unless the specified rate is higher. We will not issue revised dispensations, nor will employers need to apply for one, in order for this change to take effect. Either side can, of course, review other aspects of existing dispensations in the normal way.

This does not mean that employers must pay higher rates than their own policies require. It simply allows dispensed rates to be varied centrally, relieving both sides of the administrative burden of regular updates for this single purpose.

Current rates (from 1 July 2005) (Company Cars - Advisory Fuel Rates for Company Cars from 1 July 2005)

Earlier rates (Company Cars - Advisory Fuel Rates for Company Cars – earlier rates)

Revised rates to apply to all journeys from 1 July 2005 until further notice

Engine Size Petrol Diesel LPG
1400cc or less 10p 9p 7p
1401cc to 2000cc 12p 9p 8p
Over 2000cc 16p 13p 10p

These rates are calculated from the fuel prices in the table below:

Fuel
Engine Size (cc)
Mean MPG
Applied MPG
Fuel Price (per litre)
Fuel Price (per gallon)
Pence per mile
AFR
Petrol up to 1400 45.5 41.0 88.2 400.8 9.8 10
Petrol 1400 - 2000 37.1 33.4 88.2 400.8 12.0 12
Petrol over 2000 27.1 24.4 88.2 400.8 16.4 16
Diesel up to 2000 50.7 45.6 91.7 416.9 9.1 9
Diesel Over 2000 34.9 31.4 91.7 416.9 13.3 13
LPG up to 1400 n/a 32.8 42.0 191.0 5.8 7
LPG 1400 - 2000 n/a 26.7 42.0 191.0 7.1 8
LPG over 2000 n/a 19.5 42.0 191.0 9.8 10

Notes:

  1. Mean mpg - miles per gallon - from manufacturers information, weighted by annual sales to businesses (Society of Motor Manufacturers and Traders (SMMT), 2004). This data reflects increases in fuel economy since the original calculations were done in late 2001.
  2. Applied mpg - adjusted downwards by 10% to take account of real driving conditions and lower fuel economy for older cars.
  3. For LPG, mpg is assumed to be 20% lower due to lower volumetric energy density.
  4. Department of Trade & Industry’s latest petrol and diesel prices (June 2005), LPG from AA website (May 2005) both adjusted to include change in fuel duty announced to take effect in September 2005.
  5. LPG advisory rates are set slightly higher than the calculated pence per mile because we realise that some employers may have reached agreements with their employees on the basis of the former rates. We do not guarantee to repeat this in future and suggest that employers make agreements with employees on the basis of the rates, not the current figures.

Will the rate per mile figures change if fuel prices go up or down?

We aim to provide employers with as much certainty as possible by keeping the fuel rates unchanged where there are modest variations in fuel prices. In line with the commitment made when they were introduced, they will be reviewed during a tax year only in the event of a variation in fuel prices of greater than 10% from the prices used at that time.

VAT

HMRC will also accept the figures in the table for VAT purposes.

Rates for periods from introduction in January 2002 to 30 June 2005

The rates for these periods are:

Engine Size Petrol (entire period) Diesel (entire period) LPG (January 2002 to 5 April 2004) LPG (from 6 April 2004 to 30 June 2005)
1400cc or less 10p 9p 6p 7p
1401cc to 2000cc 12p 9p 7p 8p
Over 2000cc 14p 12p 9p 10p

How the rates for periods to 30 June 2005 were set

These figures were based on the fuel cost per mile of cars that were on sale as new during 2000 and 2001, the two years before the rates were introduced. We gave most weight to the 20 most popular fleet cars. The cars and mpg data were not updated during this period.

Company Cars - Advisory Fuel Rates for Company Cars

Processing Employer’s Annual Returns

2005 has seen a ten-fold increase in the number of Employer’s Annual Returns filed online. A whopping 935,000 Returns have come in online for 2004-05, compared to just 85,000 the year before.

We have been storing Returns in a computerised storage system whilst carrying out additional testing on our new computer system that will process them. That new system went ‘live’ on 5 June, and early last month started processing the 20 million P14s that we received via Electronic Data Interchange (EDI). Internet Returns will be processed next, followed by those submitted on paper and by magnetic media.

No employer will suffer a penalty or miss out on their online filing tax-free payment because of delays in processing Returns. We may charge a penalty if an employer has not filed on time, and large employers (250 or more employees) who had to file online may face a penalty if they did not do so. But no employer will have been put in a penalty position because of later Return processing.

Our free Online Return and Forms - PAYE service applied all our Quality Standard checks to complete and part Returns made at the time Returns were filed. For EDI Returns, we have applied all of the checks that relate to P14s and most that relate to P35s. Remaining checks were applied when EDI data was processed. For employers who have used third-party Internet-enabled software, we will be applying the full quality checks when we process their Returns; that software should have been built to our published standards and should have embodied the quality protocols. We will not, however, be rejecting any Returns where customers have used third-party software and that we hold in our storage system. We may have to contact employers later in the year where we identify problems with Returns. But we will try to fix problems ‘in-house’, and will only contact employers in exceptional circumstances.

PAYE overpayments

Once the Return Information is posted onto our systems we can identify those employers who have overpaid PAYE in 2004-05 and investigate how the overpayment happened.

Employers who need to reclaim a PAYE overpayment before their Return has been processed can reduce their next monthly or quarterly 2005-06 PAYE payment to us by the amount they think they have overpaid. (If they do so, they should send a ‘NIL’ P30B payslip for any month or quarter the overpayment is more than the amount due to us. This means we will not then send a reminder for that particular period.)

Employers who cannot recover the overpayment by reducing their next payment to us (for example, because they are not liable to make a payment of PAYE) must write to their HMRC office to claim their repayment quoting their PAYE reference. And if the 2004-05 Return was sent online, the letter must also show details of the total amount payable for the year. We will compare that with our payment records and make any repayment due. Employers must also say if they want the repayment to go to an agent, and give us the name and address of who they want us to send the repayment to. (This can be done on form R38 (PDF 38K)).

Repayments made this way are provisional and we may adjust the amount once we have processed the Return. And employers who sent their Return online must only claim a repayment where they have had our acceptance message for every part of their online Return.

£250 online filing tax-free payments

Employers with fewer than 50 employees and who filed online do not have to wait until we have processed their Return before they can claim their £250 tax-free online filing payment. They can get the benefit of the tax-free payment immediately by deducting the amount from their next 2005-06 remittance. Before reducing payment(s) to us, employers must have had an acceptance message for sending their Return online. (See April’s Tax Bulletin.)

If an employer prefers to have their £250 paid to them by cheque, we can only send that cheque after we have fully processed the Return and sent the employer written confirmation that the tax-free payment is due. We will take off anything that the employer owes us and pay the balance, and will not send a cheque if any Returns for earlier years are outstanding. Employers using an R38 to claim repayments or the tax-free payment as a cheque must tell us if the amount of the repayment sent to a third party is to be restricted to the online filing tax-free payment.

Repayments to employees

We cannot review employees’ tax liabilities until Returns have been processed and employee information has been sent to our other systems. But we can review the liability if the employee gives us their P60. And where a P60 cannot be produced, we will check pay and tax details with the employer. This year, we can make repayments to employees where the P60 is printed on plain paper.

Reminders - we are sorry

In mid-June we sent some employers online filing penalty notices, or reminders for P11Dbs, even though they had already filed online or P11Dbs were not due. There have also been isolated cases where our staff approached employers for their Return and/or warned the employers that they may have incurred penalties for filing late. As soon as we found out that these things were happening we put a stop to them immediately, and we are very sorry for any inconvenience caused.

An Update on Double Taxation Agreements (DTAs)

Annual Review

The Government reviews the UK’s treaty priorities each year to ensure that the DTA network continues to meet the needs of those conducting business overseas or receiving income from abroad. HM Revenue and Customs monitors the effectiveness of the UK’s DTAs and invites representations from business, individuals, representative bodies, other Government departments and others with an interest in this area. The comments received provide useful information on problems experienced with existing treaties and potential gaps in the treaty network.

The Paymaster General, Dawn Primarolo MP, recently announced details of the negotiating programme for DTAs for the year to 31 March 2006. Full details were given in the HM Revenue and Customs News Release NAT 16/05 issued on 12 July 2005 and a summary is given below.

DTA Negotiating Programme

  • We plan to complete work on new treaties with Botswana, the Cayman Islands, Iran, Japan and Poland.
  • We intend to progress negotiations with China, the Faroe Islands, Germany, Hungary, Hong Kong, Italy, Luxembourg, the Netherlands, Saudi Arabia and Thailand.
  • We also intend to progress negotiations with the Crown Dependencies and Overseas Territories on Tax Information Exchange Agreements.

New / Exploratory Talks

We have plans for new DTAs with the Faroe Islands and Macedonia and a Protocol with Mexico. We will make further announcements about talks with other countries as and when arrangements are made.

Representations on these and other negotiations are welcome (see the section below for details). We will generally invite country-specific representations through a News Release shortly before we begin any initial negotiations.

Recent Developments

Canada

The third Protocol to the UK/Canada DTA, signed in London on 7 May 2003, entered into force on 4 May 2004. The provisions of the Protocol apply in the UK from 1 April 2005 (for corporation tax) and from 6 April 2005 (for income tax and capital gains tax). The provisions of the Protocol apply in Canada from 1 January 2005.

Cayman Islands

A second round of talks on a comprehensive DTA was held in London in the week of 4 April 2005.

Chile

The DTA with Chile, signed in London on 12 July 2003, entered into force on 21 December 2004. The provisions of the DTA apply in the UK from 1 April 2005 (for corporation tax) and from 6 April 2005 (for income tax and capital gains tax). The provisions of the DTA apply in Chile from 1 January 2005.

China

A first round of negotiations took place in Beijing in the week of 16 May 2005.

Georgia

The DTA with Georgia, signed in London on 13 July 2004, was approved by Parliament on 6 December 2004.

Hungary

A first round of negotiations took place in Budapest in the week of 6 June 2005.

Italy

The second round of negotiations took place in Rome in the week of 27 September 2004.

Japan

The final round of negotiations was held in Tokyo in the week of 23 May 2005 and an agreement has been reached in principle (see News Release NAT 11/05 issued on 1 July 2005 for further details).

The Netherlands

The second round of negotiations took place in The Hague in November 2004.

New Zealand

The Protocol to the UK/New Zealand DTA, signed in London on 4 November 2003, entered into force on 23 July 2004. The provisions of the Protocol apply in the UK from 1 April 2005 (for corporation tax) and from 6 April 2005 (for income tax). The provisions of the Protocol generally apply in New Zealand from 1 January 2005. However, provisions relating to capital gains and the exchange of information apply in both countries from 4 November 2003.

Switzerland

A first round of talks took place in London in the week of 20 June 2005.

EU Savings Directive agreements

EU Savings Directive agreements with Guernsey, Jersey and the Isle of Man, concluded on 19 November 2004 were approved by Parliament on 14 March 2005. EU Savings Directive agreements with Member States’ dependent and associated territories in the Caribbean, concluded between December 2004 and April 2005 were approved by Parliament on 24 May 2005. The provisions of all the EU Savings Directive agreements apply from 1 July 2005.

Representations

General representations concerning new DTAs, or suggestions about changes to existing agreements, are welcomed and should be addressed to:


HM Revenue and Customs
3rd Floor (Room 3C/20/07)
100 Parliament Street
London
SW1A 2BQ

Queries regarding the effects of a DTA on a particular taxpayer’s tax liability should always be referred to the tax office responsible for dealing with their tax affairs.

Further Information

Further information on double taxation and related issues can be obtained via the Internet on the HM Revenue and Customs website

Copies of double taxation agreements published from 1997 onwards can be found on the Stationery Office’s website at www.hmso.gov.uk or purchased via www.tso.co.uk

Copies of older agreements can be obtained from the Stationery Office - Telephone 0870 600 5522. The Statutory Instrument number should be quoted (see the following list).

General double taxation issues arising in connection with estates, inheritances and gifts should be addressed to:


HM Revenue & Customs
Capital Taxes Policy Group
Integrated Business Streams
Room G73
100 Parliament Street
London
SW1A 2BQ

United Kingdom Double Taxation Agreements - Position as at 1 July 2005

Notes

Type of Agreement: The term Comprehensive refers to a DTA concerning taxes on income, and sometimes also taxes on capital gains; Limited means a DTA dealing solely with taxes on profits from air transport (a) and/or shipping (s); Estates refers to a DTA which deals with taxes on estates, inheritances and gifts; a Protocol is an amendment to an existing DTA. In all cases reference is necessary to the text of the DTA to ascertain the specific taxes dealt with.

The official designation of the DTA is indicated by:
(C): convention; (Ag): agreement; (Ar): arrangement; (P): protocol; (ex): except IHT imposed on lifetime gifts

The date of signature is given in the second column; an asterisk (*) indicates the date of the Order in Council, in the case of DTAs which do not contain signatures.

All DTAs have completed Parliamentary procedures in the UK and are in force (unless otherwise annotated).

No mention is made in this list of negotiations in progress or DTAs that have been signed but not yet approved by Parliament.

  • The former Soviet Union:
  • Statement of Practice 4/01 explains the present position.
  • Former Yugoslavia: The United Kingdom’s Double Taxation Convention with Yugoslavia (SI 1981 No.1815) is currently to be regarded as in force between the United Kingdom and Bosnia-Herzegovina, Croatia, Macedonia, Serbia and Montenegro and Slovenia (Statement of Practice 3/04 supersedes Statement of Practice 6/93).
Country Type of Agreement Date of Signature Statutory Instrument: Year/Number Notes
Algeria Limited (a) (Ag) 27.05.81 1984 No.362
-
Antigua and Barbuda Comprehensive (Ar) 19.12.47* 1947 No.2865
-
Antigua and Barbuda Protocol (Ag) 05.12.68 1968 No.1096
-
Argentina Comprehensive(C) 03.01.96 1997 No 1777
-
Armenia
-
-
-
former UK-USSR DTA ceased to apply wef 6.4.02 (SP4/01)
Australia Comprehensive (C) 21.8.03 2003 No 3199
-
Austria Comprehensive (C) 30.04.69 1970 No.1947
-
Austria Protocol (P) 17.11.77 1979 No.117
-
Austria Protocol (P) 18.05.93 1994 No.768
-
Azerbaijan Comprehensive (C) 23.02.94 1995 No.762
-
Bangladesh Comprehensive (C) 08.08.79 1980 No.708
-
Barbados Comprehensive (Ag) 26.03.70 1970 No.952
-
Barbados Protocol (P) 18.09.73 1973 No.2096
-
Belarus Comprehensive (C) 31.07.85 1986 No.224 Continuation of DTA with Soviet Union
Belarus Comprehensive (C) 07.03.95 1995 No.2706 Not yet inforce
Belgium Comprehensive (C) 01.06.87 1987 No.2053
-
Belize Comprehensive (Ar) 19.12.47 1947 No.2866 DTAs with British Honduras
Belize Protocol (Ar) 08.04.68 1968 No.573
-
Belize Protocol (Ar) 12.12.73 1973 No.2097
-
Bolivia Comprehensive (C) 03.11.94 1995 No.2707
-
Bosnia-Herzegovina Comprehensive (C) 06.11.81 1981 No.1815 DTA with Yugoslavia still applies
Botswana Comprehensive (Ag) 05.10.77 1978 No.183
-
Brazil Limited (a & s) (Ag) 08.04.68* 1968 No.572
-
Brunei Comprehensive (Ar) 08.12.50* 1950 No.1977
-
Brunei Protocol (Ar) 04.03.68* 1968 No.306
-
Brunei Protocol (Ar) 12.12.73* 1973 No.2098
-
Bulgaria Comprehensive (C) 16.09.87 1987 No.2054
-
Burma (Myanmar) Comprehensive (Ag) 13.03.50 1952 No.751
-
Burma (Myanmar) Protocol (P) 04.04.51  
-
Cameroon Limited (a) (Ag) 11.09.81 1982 No.1841
-
Canada Comprehensive (C) 08.09.78 1980 No.709
-
Canada Protocol (P) 15.04.80 1980 No.1528
-
Canada Protocol (P) 16.10.85 1985 No.1996
-
Canada Protocol (P) 07.05.03 2003 No 2619
-
Chile Comprehensive 12.7.03 2003 No 3200
-
China Comprehensive (Ag) 26.07.84 1984 No.1826
-
China Protocol (P) 02.09.96 1996 No 3164
-
Croatia Comprehensive (C) 06.11.81 1981 No.1815 DTA with Yugoslavia still applies
Cyprus Comprehensive (C) 20.06.74 1975 No.425
-
Cyprus Protocol (P) 02.04.80 1980 No.1529
-
Czech Republic Comprehensive (C) 05.11.90 1991 No.2876 DTA with Czechoslovakia still applies
Denmark Comprehensive (C) 11.11.80 1980 No.1960
-
Denmark Protocol (P) 01.07.91 1991 No.2877
-
Denmark Protocol (P) 15.10.96 1996 No 3165
-
Egypt Comprehensive (C) 25.04.77 1980 No.1091
-
Estonia Comprehensive (C) 12.05.94 1994 No.3207
-
Ethiopia Limited (a) (Ag) 01.02.77 1977 No.1297
-
Falkland Islands Comprehensive 17.12.97 1997 No 2985
-
Fiji Comprehensive (C) 21.11.75 1976 No.1342
-
Finland Comprehensive (C) 17.07.69 1970 No.153
-
Finland Protocol (P) 17.05.73 1973 No.1327
-
Finland Protocol (2nd.P) 16.11.79 1980 No.710
-
Finland Protocol (3rd.P) 01.10.85 1985 No.1997
-
Finland Protocol (4th.P) 26.09.91 1991 No.2878
-
Finland Protocol (P) 31.07.96 1996 No 3166
-
France Comprehensive (C) 22.05.68 1968 No.1869
-
France Protocol (P) 10.02.71 1971 No.718
-
France Protocol (P) 14.05.73 1973 No.1328
-
France Protocol (P ) 12.06.86 1987 No.466
-
France Protocol (4th.P) 15.10.87 1987 No.2055
-
France Estates (C) (ex) 21.06.63 1963 No.1319
-
Gambia Comprehensive (C) 20.05.80 1980 No.1963
-
Georgia Comprehensive (Ag) 13.07.04 2004 No. 3325 Not yet in force former UK-USSR DTA ceased to wef 6.4.02 (SP4/01)
Germany Comprehensive (C) 26.11.64 1967 No.25
-
Germany Protocol (P) 23.03.70 1971 No.874
-
Ghana Comprehensive (C) 20.01.93 1993 No.1800
-
Greece Comprehensive (C) 25.06.53 1954 No.142
-
Grenada Comprehensive (Ar) 04.03.49* 1949 No.361
-
Grenada Protocol (Ag) 25.07.68 1968 No.1867
-
Guernsey Comprehensive (Ar) 24.06.52* 1952 No.1215
-
Guernsey Protocol (Ar) 14.12.94* 1994 No.3209
-
Guyana Comprehensive (C) 31.08.92 1992 No.3207
-
Hong Kong Limited (a) air transport 25.07.97 1998 No 2566
-
Hong Kong Limited (a) shipping 25.10.00 2000 No 3248
-
Hungary Comprehensive (C) 28.11.77 1978 No.1056
-
Iceland Comprehensive (C) 30.09.91 1991 No.2879
-
India Comprehensive (C) 25.01.93 1993 No.1801
-
India Estates (Ag) (ex) 03.04.56 1956 No.998
-
Indonesia Comprehensive (Ag) 05.04.93 1994 No.769
-
Iran Limited (a) (Ag) 21.12.60* 1960 No.2419
-
Ireland, Republic of Comprehensive (C) 02.06.76 1976 No.2151
-
Ireland, Republic of Protocol (P) 28.10.76 1976 No.2152
-
Ireland, Republic of Protocol (P) 07.11.94 1995 No.764
-
Ireland, Republic of Protocol (P) 04.11.98 1998 No 3151
-
Ireland, Republic of Estates (C) 07.12.77 1978 No.1107
-
Isle of Man Comprehensive (Ar) 29.07.55 1955 No.1205
-
Isle of Man Protocol (Ar)
-
1991 No.2880
-
Isle of Man Protocol (Ar) 14.12.94* 1994 No.3208
-
Israel Comprehensive (C) 26.09.62 1963 No.616
-
Israel Protocol (P) 20.04.70 1971 No.391
-
Italy Comprehensive (C) 21.10.88 1990 No.2590
-
Italy Estates (C) (ex) 15.02.66 1968 No.304
-
Ivory Coast (Cote D’ivoire) Comprehensive (C) 26.06.85 1987 No.169
-
Jamaica Comprehensive (Ag) 16.03.73 1973 No.1329
-
Japan Comprehensive (C) 10.02.69 1970 No.1948
-
Japan Protocol (P) 14.02.80 1980 No.1530
-
Jersey Comprehensive (Ar) 24.06.52* 1952 No.1216
-
Jersey Protocol (Ar) 14.12.94* 1994 No.3210
-
Jordan Limited (a & s) (Ag) 06.03.78* 1979 No.300
-
Jordan Comprehensive (C) 22.07.01 2001 No 3924
-
Kazakstan Comprehensive (C) 21.03.94 1994 No.3211
-
Kazakstan Protocol (P) 18.09.97 1998 No 2567
-
Kenya Comprehensive (Ag) 31.07.73 1977 No.1299
-
Kenya Protocol (P) 20.01.76
-
-
Kiribati Comprehensive (Ar) 10.05.50* 1950 No.750 DTAs with Gilbert and Ellice Islands
Kiribati Protocol (Ar) 04.03.68* 1968 No.309
-
Kiribati Protocol (Ar) 25.07.74* 1974 No.1271
-
Korea (S) Comprehensive (C) 25.10.96 1996 No.3168
-
Kuwait Comprehensive (C) 21.07.99 1999 No 2036
-
Kyrgyzstan
-
-
-
Former UK-USSR DTA ceased to apply wef 6.4.02 (SP4/01)
Latvia Comprehensive (C ) 08.05.96 1996 No.3167
-
Lebanon Limited (a & s) (Ag) 26.02.64* 1964 No.278
-
Lesotho Comprehensive 17.12.97 1997 No 2986
-
Lithuania Comprehensive 19.3.01 2001 No 3925
-
Lithuania Protocol 21.5.02 2002 No 2847
-
Luxembourg Comprehensive (C) 24.05.67 1968 No.1100
-
Luxembourg Protocol (P) 18.07.78 1980 No.567
-
Luxembourg Protocol (2nd.P) 28.01.83 1984 No.364
-
Macedonia Comprehensive (C) 06.11.81 1981 No.1815 DTA with Yugoslavia still applies
Malawi Comprehensive (Ar) 25.11.55 1956 No.619 1955 DTA with Federation of Rhodesia and Nyasaland
Malawi Protocol (Ag) 02.09.64* 1964 No.1401
-
Malawi Protocol (Ag) 12.07.68* 1968 No.1101
-
Malawi Protocol (Ag) 10.02.78 1979 No.302
-
Malaysia Comprehensive 17.12.97 1997 No 2987
-
Malta Comprehensive (C) 12.05.94 1995 No.763
-
Mauritius Comprehensive (C) 11.02.81 1981 No.1121
-
Mauritius Protocol (P) 23.10.86 1987 No.467
-
Mauritius Protocol (P) 27.03.03 2003 No 2620
-
Mexico Comprehensive (C) 02.06.94 1994 No.3212
-
Moldova
-
-
-
Former UK-USSR DTA ceased to apply wef 6.4.02 (SP4/01)
Mongolia Comprehensive (C) 23.04.96 1996 No.2598
-
Montserrat Comprehensive (Ar) 19.12.47* 1947 No.2869
-
Montserrat Protocol (Ar) 08.04.68* 1968 No.576
-
Morocco Comprehensive (C) 08.09.81 1991 No.2881
-
Myanmar - see Burma
-
-
-
-
Namibia Comprehensive (C) 28.05.62 1962 No.2788 Extension of UK – South Africa DTA (SI 1962 No.2352) to South West Africa
Namibia Protocol (P) 14.06.67 1967 No.1490 Extension of UK – South Africa protoc(SI 1967 No.1489)South West Africa
Netherlands Comprehensive (C) 07.11.80 1980 No.1961
-
Netherlands Protocol (P) 12.07.83 1983 No.1902
-
Netherlands Protocol (P) 24.07.89 1990 No.2152
-
Netherlands Estates (C) 11.12.79 1980 No.706
-
Netherlands Protocol (P) 07.09.95 1996 No.730
-
New Zealand Comprehensive (C) 04.08.83 1984 No.365
-
New Zealand Protocol 04.11.03 2004 No.1274
-
Nigeria Comprehensive (Ag) 09.06.87 1987 No.2057
-
Norway Comprehensive (C) 12.10.00 2000 No 3247
-
Oman Comprehensive (C) 23.02.98 1998 No 2568
-
Pakistan Comprehensive (C) 24.11.86 1987 No.2058
-
Pakistan Estates (Ag) (ex) 08.06.57 1957 No.1522
-
Papua New Guinea Comprehensive 17.09.91 1991 No.2882
-
Philippines Comprehensive (C) 10.06.76 1978 No.184
-
Poland Comprehensive (C) 16.12.76 1978 No.282
-
Portugal Comprehensive (C) 27.03.68 1969 No.599
-
Romania Comprehensive (C) 18.09.75 1977 No.57
-
Russia Comprehensive (C) 15.2.94 1994 No 3213
-
St.Christopher (St.Kitts) and Nevis Comprehensive (Ar) 19.12.47* 1947 No.2872
-
Saudi Arabia Limited (a) 10.03.93 1994 No.767
-
Serbia and Montenegro Comprehensive (C) 06.11.81 1981 No.1815 DTA with Yugoslavia still applies
Sierra Leone Comprehensive (Ar) 19.12.47* 1947 No.2873
-
Sierra Leone Protocol (Ag) 18.03.68 1968 No.1104
-
Singapore Comprehensive 17.12.97 1997 No 2988
-
Slovakia Comprehensive (C) 05.11.90 1991 No.2876 DTA withCzechoslovakia stillapplies
Slovenia Comprehensive (C) 06.11.81 1981 No.1815 DTA withYugoslaviastill applies
Solomon Islands Comprehensive (Ar) 10.05.50* 1950 No.748 DTAs with British Solomon Islands
Solomon Islands Protocol (Ar) 08.04.68* 1968 No.574
-
Solomon Islands Protocol (Ar) 25.07.74* 1974 No.1270
-
South Africa Comprehensive (C) 04.07.02 2002 No.3138
-
South Africa Estates (C) 31.07.78 1979 No.576
-
Spain Comprehensive (C) 21.10.75 1976 No.1919
-
Spain Exchange of Notes 15.03.95 1995 No.765
-
Sri Lanka Comprehensive (C) 21.06.79 1980 No.713
-
Sudan Comprehensive (C) 08.03.75 1977 No.1719
-
Swaziland Comprehensive (Ag) 26.11.68 1969 No.380
-
Sweden Comprehensive (C) 30.08.83 1984 No.366
-
Sweden Estates (C) 08.10.80 1981 No.840
-
Sweden Protocol (P) 21.12.87 1989 No.986
-
Switzerland Comprehensive (C) 08.12.77 1978 No.1408
-
Switzerland Protocol (P) 05.03.81 1982 No.714
-
Switzerland Protocol (P) 17.12.93 1994 No.3215
-
Switzerland Estates (C) 17.12.93 1994 No.3214
-
Switzerland Protocol (P) 17.12.93 1994 No. 3214
-
Taiwan Comprehensive (C) 08.04.02 2002 No 3137
-
Tajikistan
-
-
-
Former UK-USSR DTA applies (SP4/01).
Thailand Comprehensive (C) 18.02.81 1981 No.1546
-
Trinidad and Tobago Comprehensive (C) 31.12.82 1983 No.1903
-
Tunisia Comprehensive (C) 15.12.82 1984 No.133
-
Turkey Comprehensive (Ag) 19.02.86 1988 No.932
-
Turkmenistan
-
-
-
Former UK-USSR DTA applies (SP4/01)
Tuvalu Comprehensive (Ar) 10.05.50* 1950 No.750 DTAs with Gilbert and Ellice Islands
Tuvalu Protocol (Ar) 04.03.68* 1968 No.309
-
Tuvalu Protocol (Ar) 25.07.74* 1974 No.1271
-
Uganda Comprehensive (C) 23.12.92 1993 No.1802
-
Ukraine Comprehensive (C) 10.02.93 1993 No.1803
-
United States Comprehensive (C) 24.7.01 2002 No 2848
-
United States Protocol (P) 19.7.02
-
-
United States Estates (C) 19.10.78 1979 No.1454
-
Uzbekistan Comprehensive (C) 15.10.93 1994 No.770
-
Venezuela Comprehensive (C) 11.03.96 1996 No. 2599
-
Vietnam Comprehensive (Ag) 09.04.94 1994 No.3216
-
Yugoslavia - See note on page 1
-
-
-
-
Zaire Limited (a & s) (Ag) 11.10.76 1977 No.1298
-
Zambia Comprehensive (C) 22.03.72 1972 No.1721
-
Zambia Protocol (P) 30.04.81 1981 No.1816
-
Zimbabwe Comprehensive (C) 19.10.82 1982 No.1842
-

Trust Management Expenses

Background

In his 2003 Pre-Budget Report the Chancellor asked the Inland Revenue to look at ways of modernising the tax system for trusts and to consult with trust practitioners about those changes.

Following some initial discussions in 2003 and 2004 the overwhelming view of the trust profession was that there were some aspects relating to Trust Management Expenses (TMEs) that were unclear, but that the problem was best solved by agreeing some better guidance rather than legislating.

The Government agreed and announced in the Budget in 2004 that the Inland Revenue would seek to agree some guidance, but if that proved impossible they were prepared to legislate at a later date.

In September 2004 a discussion paper was issued.

Purpose of the discussion paper

The paper set out the Inland Revenue’s position on Trust Management Expenses, based upon an interpretation of law and practice prevailing at the time.

The intention, once the guidance was agreed, was to publish it in the notes to the trusts and estates tax return, and in the Trusts, Estates and Settlements Manual (TSEM), so that it could be used by trustees completing trust returns or notifying IIP beneficiaries of their net trust income.

Recent developments

HMRC are very grateful for the helpful and constructive comments received in response to the discussion paper. It was also pleasing that there were many areas of common agreement.

Using the feedback the discussion paper was rewritten, and was sent out for further, final, comment, last month. If anyone with an interest would like to see this latest draft please contact Marian Burns in HMRC Trusts Directors Office on 0151 472 6064

The paper was published without the originally included paragraphs about payments for trustees’ remuneration. This was a longstanding contentious issue, upon which a common view could not be established. Following discussions with the Society of Trusts and Estates Practitioners (STEP) it was agreed not to hold up the remainder of the paper because of an inability to agree over one specific point. So the paper is silent on this subject. Accordingly, until such times as the issue is resolved, the HMRC view is that, except in rare circumstances where it can be demonstrated the payments are solely for managing income, payments of trustees’ remuneration are linked to the management of the trust as a whole and are therefore regarded as attributable to capital.

It is hoped to issue the final agreed guidance by the end of September 2005.

HMRC Trusts

Recent months have seen the reorganisation of the way in which trust work is organised within HMRC.

HMRC Trusts was formed relatively recently from different parts of the Inland Revenue and the recent reorganisation was undertaken to improve the consistency of our operations, in particular improving the service we provide to our customers.

The most obvious change has been the reduction from 5 to 3 in the number of our operational offices. On 30 April 2005, London and Manchester Trust offices closed and the work was transferred to our other offices in Nottingham, Truro and Edinburgh. Full details of what these offices now deal with are available in our literature and on the HMRC web site, but broadly Edinburgh deals with all Scottish trusts, trusts with addresses in Northern Ireland, all trusts with a corporate trustee and the administration periods of all UK large deceased estates. Truro deals with trusts based in the London Boroughs and the 6 South West counties of Cornwall, Devon, Wiltshire, Somerset, Dorset and Gloucestershire. Nottingham deals with all other English trusts and trusts in Wales.

Our customers may have experienced some disruption to our service during the period this reorganisation was taking place and for this we apologise. With the reorganisation now complete we look forward to providing the much-improved service that is planned.

Business Link

businesslink.gov.uk - Easing the burden of taxes

businesslink.gov.uk, the cross-government website that provides business related information and support, can help to ease the tax burden for business. The site contains comprehensive information and tools covering all aspects of tax, from completing returns through to handling payroll.

By using businesslink.gov.uk owners and managers of small businesses can develop a good understanding of their tax and finance responsibilities, helping them to work with you, their accountant, on the more complex issues.

Online tax forms and returns

Sending or receiving information online is secure, convenient and quick. It is more reliable and efficient than using paper, and can cut down on storage space and costs. Businesses can now submit a range of tax forms and returns securely over the internet by enrolling for online services using Sign-up Manager at http://www.businesslink.gov.uk/onlinefiling.

Once enrolled, businesses will be able to send and receive a range of forms and returns over the Internet including:

  • PAYE Online for Employers can earn small businesses up to £825 tax-free over five years if they start filing online early.
  • eVAT Returns reduces paperwork and businesses can gain up to seven extra days to pay their VAT if they pay by Direct Debit.

 

Key date reminders

By answering a few questions about their businesses, owners and managers can receive a calendar of important tax-related deadlines covering the next twelve months. They can also sign up to receive regular email alerts as each date approaches. Businesses can sign up for this service at www.businesslink.gov.uk/keydates.

The No-Nonsense Guide to Government rules and regulations for setting up your business

The 2005 edition of Business Link’s most popular publication has been fully revised with changes from the Budget, the latest legislation and up-to-date contact information. The Guide highlights what entrepreneurs need to know about the legal and official side of starting up on their own, such as sorting out tax and National Insurance and protecting intellectual property.

Businesses can order their free copy from www.businesslink.gov.uk/nng or telephone Business Link on 0845 600 9 006.

Adding value

businesslink.gov.uk has attracted over 8 million visits from an audience of over 800,000 small business users each month - a figure that rises month on month. The site brings together support from over 40 Government departments and agencies, such as Her Majesty’s Revenue & Customs and the Health & Safety Executive, to develop tools and information to help managers and owners to run their businesses as efficiently as possible. 

As one of the leading sites for small business, it contains a range of practical online guides and real-life case studies which demonstrate how other companies have taken simple steps to improve their business competitiveness. They cover a range of business issues and functions such as Starting up, Finance and grants, Sales and marketing, International trade and Grow your business.

businesslink.gov.uk can also prove a valuable asset for you, enabling you to direct your clients to one authoritative source of quality, impartial information to help them start up, grow and develop their business.

Correction to Tax Bulletin Special Edition 9

TBSE9 contained the following statement in respect of claims for losses arising on quota that ceased to exist before 1 January 2005:

"Quotas that ceased before 1 January 2005 are now worthless and negligible value claims may be made. A negligible value claim may result in an allowable loss available to set against chargeable gains of the same or a later tax year where the quota had been acquired on purchase."

We apologise for the fact that this statement is incorrect. A negligible value claim cannot be made at a time when the asset in question has ceased to exist. However, quota that were abolished before 1 January 2005 will be treated as having been disposed of on the date on which they ceased to exist. Capital losses may arise in respect of quota acquired other than for nil consideration that were held as non-wasting assets. The normal claims procedure applies to allowable losses arising on the extinction of quota.

Carter review of online services

On 21 July the Paymaster General, Dawn Primarolo, announced that the Government had asked Patrick Carter to undertake a review of HMRC online services, looking at realising benefits for customers whilst ensuring that the department continues to deliver a sustainable and efficient services that supports compliance. For more information about this consultation go to Consultation documents.

Inland Revenue Statements of Practice and Extra-Statutory Concessions issued between 01/06/2005 to 31/07/2005.

Extra Statutory Concessions

There have been no Extra Statutory Concessions for this period

Statements of Practice

There have been no Statements of Practice for this period

You can get the latest copies of SPs and ESCs by telephoning on 020 7147 2363.

Content

The content of Tax Bulletin gives the views of our technical specialists on particular issues. The information published is reported because it may be of interest to tax practitioners. Publication will be six times a year, and include a cumulative index issued on an annual basis.

  • You can expect that interpretations of the law contained in the Bulletin will normally be applied in relevant cases, but this is subject to a number of qualifications.
  • Particular cases may turn on their own facts, or context, and because every possible situation cannot be covered, there may be circumstances in which the interpretation given here will not apply.
  • There may also be circumstances in which the Board would find it necessary to argue for a different interpretation in appeal proceedings.
  • The Bulletin does not replace formal Statements of Practice.
  • The Board’s view of the law may change in the future. Readers will be notified of any changes in future editions.
  • All the names used in examples and illustrations are imaginary and have no relation to real persons, living or dead, except by coincidence

Nothing in this Bulletin affects a taxpayer’s right of appeal on any point.


About the Author

© Crown Copyright 2006.

A Licence is need to reproduce this article and has been republished for educational/ informational purposes only. Article reproduced by permission of HM Revenue & Customs under the terms of a Click-Use Licence. Tax bulletins are updated regularly and may be out of date at time of reading.


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