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Tax Bulletin Issue 84

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HM Revenue and Customs -Tax Authorities

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August 2006

Contents

Miscellaneous

 

Self Assessment Tax Returns Foreign Savings & Dividend Income - Remittance Basis of Taxation

Dividend Income

In the process of introducing the Income Tax (Trading & Other Income) Act 2005 (ITTOIA) an inadvertent change was made to the law. This affects the rate of tax chargeable on foreign dividend income that is taxable on the alternative basis provided by Part 8 of ITTOIA (commonly known as the remittance basis).

From 6 April 2005 the top rate of tax chargeable on foreign dividend income on the remittance basis is 32.5% and not 40%. As this change did not come to light until after the 2005/06 self assessment return and tax calculator had been compiled and issued the self assessment system will automatically apply the former tax rate of 40% for higher rate taxpayers.

This situation potentially only affects a very small number of individuals who can claim the remittance basis of taxation, are liable to income tax at the higher rate, and will be including on page F2 (of the Foreign Pages) dividend income from a non-UK company calculated by reference to the amount received in the UK in the tax year. This note provides guidance that will help rectify the issue for people affected.

The action to be taken by any person affected will depend on how they approach their self assessment tax return:

  • Individuals who file paper returns and ask HMRC to calculate the tax due:

Should draw attention to the inclusion of the foreign dividend income in the Additional Information box 23.9 on page 10 of the Main Return. A note along the lines, “HR tax may be payable on foreign dividen income of £xx included on page F2 on the remittance basis” will draw attention to the fact that an amendment to the automatic calculation is needed. The note should also be made if the person is unsure whether higher rate tax is due. No note is needed if tax is only due at basic or starting rates.

  • Individuals who file paper returns and calculate their own tax:

Should calculate any top rate tax due on remittance basis foreign dividend income using the dividend upper rate of 32.5%. As the self assessment system will be expecting tax on such income to be charged at 40% an explanation should be given in the Additional Information box 23.9 on page 10 of the Main Return. This could be along the lines, “HR tax has been calculated at 32.5% on foreign dividend income of £xx included on page F2 on the remittance basis”. It will help us to amend the automatic tax calculation before the statutory payment date if returns in these cases are sent in as early as possible.

  • Individuals who file their tax return online:

Should file the return using the tax rate the software gives. This affects customers who file online using third party commercial software, either directly or, for example, through a professional adviser and who need to complete the supplementary Foreign Pages. For 2005/2006 the software will calculate the tax due for a higher rate taxpayer on foreign dividend income chargeable on the remittance basis at 40%. So, if a return is filed online, a note along the lines, “HR tax has been calculated at 40% instead of 32.5% on foreign dividend income of £xx included on the remittance basis” should be included as ‘Additional Information’. HMRC will then make any necessary adjustment after the return has been filed electronically. It will help us to amend the tax calculation before the statutory payment date if returns in these cases are sent in as early as possible.

Savings (Interest) Income

There is an error in the notes and examples at page FN3 (Example 3) and FN15 (Example 9) of the Notes on Foreign pages.

This affects UK resident individuals receiving payments that have been subjected to Special Withholding Tax (SWT) described on page FN3. But who are making their return in respect of those payments by reference to amounts received in the UK in respect of the income or gain (the remittance basis).

In Example 3, under the heading “Foreign Income taxed on the remittance basis” on page FN3, the final line should indicate that the full amount of SWT (that is £150 in the example) should be entered on the return at column D. The remainder of the example is correct. The opening sentence above the example should read:

“If you have claimed for your foreign income to be taxed on the remittance basis you can still claim the Special Withholding Tax that relates to the income arising during
this year”.

Similarly in Example 9, under the heading “Relief for Special Withholding Tax paid on gains” on page FN15, the final sentence should indicate that the full amount of SWT (that is £3,000 in the example) should be entered on the return at box 6.10A. The final sentence of the paragraph above the example should read:

“If Capital Gains Tax is payable by reference to the amount of the gain received in the UK you can still claim the Special Withholding Tax that relates to the whole gain that has accrued in the year”.

ICTA88/S703: Interest on tax

This article draws attention to the corrrect practice for interest on tax charged in assessments made in accordance with a notice under ICTA88/S703(3).

ICTA88/S703 - 709 are anti avoidance provisions which enable HMRC to counteract tax advantages obtained by a person in consequence of a transaction in securities in one of
the circumstances described in Section 704 A – E. These provisions apply to income tax and corporation tax. HMRC exercises its functions under these provisions through the Clearance and Counteraction Team of the Anti Avoidance Group. You can read more about these provisions in the
guidance provided to HMRC staff in the Company Tax Manual at paragraph CTM36805 onwards.

The procedure in ICTA88/S703(3) provides for HMRC to specify the form of counteraction in a notice to the person concerned. In practice in most cases the notice specifies that an assessment is to be made to charge the tax that would otherwise have been avoided.

We have recently received legal advice about the basis on which interest is charged on assessments to income tax and corporation tax made in accordance with a notice under ICTA88/S703(3). Income tax charged in such an assessment is payable in accordance with TMA70/S59B(6) and carries interest from the ‘relevant date’ until payment (TMA70/S86(2)). The ‘relevant date’ is the 31 January following the end of the year of assessment (TMA70/S86(2)(b) and S59B(4)). Corporation tax charged in such an assessment is payable under TMA70/S59D and
carries interest from nine months after the end of the accounting period (TMA70/S87A).

We had previously believed that such assessments carried interest only from thirty days after the assessment was actually made. We recognise that this view (‘the old practice’) was wrong. Interest is now charged on the correct basis as explained in the previous paragraph.

In practice most S703 counteraction cases are settled by agreement between HMRC and the taxpayer. Tax due is often paid under a contract settlement. Such settlements need to include a sum in consideration of interest calculated on the correct basis as explained above.

At any time, we may be discussing with a number of taxpayers and their advisers the application of S 703 in respect of particular transactions. Exceptionally, a small number of these taxpayers may be able to demonstrate that, before the date of this Tax Bulletin, they had been led by us
to believe that interest would not be charged except in accordance with the old practice and that they have entered into settlement negotiations with us on that basis. In such a case, we may continue to apply the old practice for periods up to the date of this Tax Bulletin. In all other cases, the correct basis will be applied.

ICTA88/S707 provides a procedure by which HMRC can give a person clearance that no notice will be issued to them under ICTA88/S703(3) for a particular transaction or transactions. Please check the Clearances and approvals provided for in the Taxes Acts for current information on sending us clearance applications.

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.

Finance Act 2005 introduced two 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.

Finance Act 2006 has introduced further measures and these are summarised below. They all apply from 6 April 2006 with the exception of the common residence test, which will apply
from 6 April 2007. These measures apply to family/personal types of trust, not to unit trusts, Venture Capital Trusts or other specialised vehicles that, whilst called trusts, have their
own separate taxing system or are taxed as corporations.

Trustees treated as a single person and one return per trust or settlement

From 6 April 2006 trustees of a settlement are treated as a single person and this deemed person is distinct from the actual persons (individuals and/or companies) who act as the trustees. Section 685E(1) ICTA 1988 therefore brings the income tax treatment into line with the existing CGT
treatment in an amended section 69(1) TCGA 1992.

A consequence of treating the trustees as a single body for both income tax and CGT is that, in the absence of a sub-fund election (see below), a trust or settlement is treated as a single settlement regardless of the number of funds there may be. It is therefore no longer possible to submit.

separate income tax returns for different funds within a settlement even if those funds have different trustees. Where this practice has been adopted in the past the trustees will
have to submit one return for 2006-07 and later years for the entire trust or settlement unless they make a sub-fund election.

There are now common definitions for both the general purposes of income tax and CGT of ‘settlor’ and ‘settled property’ in sections 685A and 685B ICTA 1988 and sections 68 and 68A TCGA 1992. These are based on the existing CGT definitions. They do not apply to Chapter 5 of Part 5 of
ITTOIA 2005 (amounts treated as income of the settlor).

Sub-fund elections

Trustees of a settlement can elect for a fund or other specified portion of the settled property (referred to as the “sub-fund”) to be treated as a separate settlement for tax purposes. The trustees of the sub-fund are treated as the trustees of that separate settlement and not the principal settlement, unless they are also a trustee of the principal settlement. There is a deemed disposal for CGT purposes of the property within the sub-fund by the trustees of the principal settlement and a deemed acquisition by the trustees of the sub-fund. There is no hold-over relief in such cases unless it is available under the normal CGT rules.

The trustees have to satisfy four conditions for the election to be effective:

  • The principal settlement must not itself be a sub-fund settlement.
  • There must be some property comprised in the principal settlement which is not in the sub-fund.
  • Property cannot be co-owned by the trustees of the principal settlement and the trustees of the sub-fund settlement.
  • Subject to certain exceptions, a person cannot be a beneficiary under both the principal settlement and the sub-fund settlement.

The election must be made on a prescribed form, which will be available shortly on the HMRC website. It can be completed on screen but must then be printed and signed by all the trustees of the settlement, including, where they are different, the trustees of funds within the settlement. In view of this it is not possible to submit the form electronically. Trustees or their agents who do not have internet access should contact the Trusts office dealing with the tax affairs of the settlement for a paper version of the form.

Once a valid election is in place the sub-fund is treated as a separate settlement for all tax purposes with the exception of the annual exempt amount for CGT. The sub-fund does not
have its own annual exempt amount. Instead the amount that would have been available to the principal settlement if there had been no election is divided equally between the principal
and its sub-funds, insofar as they are not excluded settlements (as defined in paragraph 2(7) of Sch 1 TCGA 1992).

Capital sums treated as income

Certain sums that are capital in general trust law are deemed to be income for tax purposes, for example, a company purchase of its own shares and certain lease premiums. Section 686A ICTA 1988 has been amended to introduce a common charging mechanism for the various types of capital receipt currently assessable to income tax in the trustees’ hands under a variety of charging mechanisms.

These sums are now all chargeable at the special trust rates (32.5% in respect of income that is treated as dividend income and 40% in respect of other deemed income) from 6 April 2006. They include three types of capital sum (certain lease premiums, transactions in deposit rights and certain transactions in land) that have previously been treated as income but have not until now been chargeable at the special trust rates. The ‘Exceptional deductions’ entry at box 13.22 in
the Trust and Estate Return, previously used to record these three types of capital sum so that the special trust rates did not apply to them, will be withdrawn.

Income tax chargeable at the special trust rates (excluding any amount covered by a non-payable or notional tax credit attaching to the deemed income) in respect of all these capital sums will now be included in the tax pool for the purposes of s687(3) ICTA 1988. So, for example, the additional tax payable on chargeable event gains will now enter the tax pool but the notional tax credit of 20% will not.

The capital sums that are treated as income are payments from or gains or profits arising on:

  • a company purchase of its own shares,
  • chargeable event gains on contracts for life insurance etc,
  • the disposal of deeply discounted securities, where the trustees are resident in the UK,
  • lease premiums,
  • the disposal of futures and options,
  • the disposal of deposit rights,
  • the disposal of foreign dividend coupons,
  • chargeable event gains arising to Employee Share Ownership Trusts,
  • offshore income gains and
  • the disposal of land, to which section 776 ICTA 1988 applies.

Standard rate band

Section 686D ICTA 1988 introduced a standard rate band, whereby the first £500 of income that would otherwise be chargeable at the special trust rates is instead chargeable at the basic (22%), savings (20%) or dividend ordinary (10%) rates, depending on the nature of the income. From
6 April 2006 the standard rate band has been raised to £1,000.

A new s686E ICTA 1988 further modifies the standard rate band where a settlor has made more than one settlement. Where this is the case the standard rate band for each such settlement is reduced by dividing £1,000 by the total number of settlements, though it cannot be reduced to less than £200. Any settlement that is in existence during any part of the tax year counts towards the total number of the settlor’s settlements. If there is more than one settlor, the amount is
reduced by reference to the settlor with the highest number of settlements. Where a sub-fund election has been made, the sub-fund is treated as a separate settlement and so must
be included in the total number of the settlor’s settlements.

A new Question 9A will be included in the Trust and Estate Return for 2006-07 and later years to enable trustees to state the amount of standard rate band to which they are entitled.

Settlor-interested trusts and settlements

Section 686(2)(b) ICTA 1988 has been amended and from 6 April 2006 the trustees of settlor-interested trusts are no longer taken out of the charge to the special trust rates. The normal rules for accumulation and discretionary trusts will therefore apply in these cases, so that dividend income is assessable at 32.5% and all other income is assessable at the rate applicable to trusts, currently 40%. As a result boxes 13.1 to 13.6 in Question 13 of the Trust and Estate return will
be removed.

In addition income which is treated as income of the settlor for tax purposes, whether from a trust or from a settlement, will retain its character in the hands of that person. Section 619 ITTOIA 2005 has been amended so that the income will now be chargeable in the same way as would have been the case had the income arisen directly to that person. It is therefore chargeable at that person’s marginal rates and carries a credit for any tax paid by trustees - this could be 10%, 20%, 22%, 32.5% or 40% depending on the nature of the trust and income.

This income should be returned on the Trusts Etc supplementary pages (SA107) and the notes in the Return Guide for 2006-07 and later years will be amended accordingly. The settlor cannot use any actual loss, from sources such as a trade, incurred by the trustees to set off against other personal income. The new rules apply to income arising or treated as arising on or after 6 April 2006 and to income paid to a settlor’s minor child, on or after 6 April 2006, whenever the income arose.

A new section 685A ITTOIA 2005 provides a statutory basis for the existing practice of not taxing beneficiaries of settlor-interested trusts on discretionary income they receive from the trustees where the underlying income has already been taxed on the settlor under section 619 ITTOIA 2005. The beneficiary is treated as having paid income tax at the higher rate in respect of the payment but this tax treated as paid is not repayable and cannot be set off against any other
liability of the beneficiary. A new box will be included in the Trusts Etc supplementary pages (SA107) for 2006-07 and later years so that beneficiaries can return this income. The
trustees do not have to account for the tax treated as paid but they cannot include it in the tax pool.

Where only part of the income is chargeable on the settlor, the beneficiary is treated as having paid income tax at the higher rate only on a proportion of the discretionary payment, corresponding to the proportion of income chargeable on the settlor to the total income of the trustees.

A settlor of a settlor-interested trust may also be a beneficiary of that trust. If so, he or she will still be chargeable under section 619 ICTA 1988 on the income arising to the trustees.
The settlor does not then need to include details of discretionary payments received from the trustees in the Trusts Etc supplementary pages (SA107) as he or she is already taxable on the underlying income.

The definitions of ‘settlor-interested’ for CGT purposes in section 77 TCGA 1992 and section 169F TCGA 1992 have been extended and from 6 April 2006 a settlor is regarded as having an interest in a settlement if any of the settled property, or property derived from it, is, will or may become
payable to, or applied for the benefit of, a dependent child of the settlor. A dependent child is a child, including a stepchild, who is under 18 and neither married nor in a civil partnership. This change in the definition does not mean that bare trusts for minors will now be treated as settlor-interested settlements. There has been no change to the tax treatment of bare trusts and gains will continue to be chargeable on the beneficiary.

The measure also includes a provision that prevents the extended definition applying in a case where special CGT treatment would apply to a vulnerable beneficiary. So the fact that a parent of a vulnerable person, who as a settlor of the settlement, is now treated as having an interest in the settlement solely because of the amendment of s77 TCGA 1992, is disregarded. A gain where special capital gains tax treatment would otherwise be available will not be chargeable on the settlor and the special tax treatment will still apply. But if the settlor is treated as having an interest in the settlement for any other reason then, just as before, the special tax treatment will not be available.

Residence test

Section 685E(2) – (7) ICTA 1988 and an amended S69(2) TCGA 1992 provide a common residence test for trustees, based on the existing income tax definition. The new test applies from 6 April 2007, a year later than the other measures. From that date the trustees of a settlement are
treated as resident and ordinarily resident for both income tax and CGT if they are all resident in the United Kingdom.

If some of the trustees are resident and ordinarily resident but some are not they are treated as resident if any settlor in relation to the settlement is resident, ordinarily resident or domiciled in the UK at any relevant time. If the settlor in this situation is not resident, ordinarily resident or domiciled in the UK or if none of the trustees is resident, then the trustees (the ‘deemed person’) are treated as not resident or ordinarily resident.

‘Relevant time’ in relation to a settlor means:

  • where the settlement arose on the settlor’s death, the time immediately before his or her death,
  • in any other case, any time at which the settlor made, or is treated as making, the settlement.

Currently, UK resident professional trustees can be treated as not resident for CGT purposes, where the settlor is neither UK resident nor domiciled at any relevant time. Once the new residence test applies this will no longer be possible. In such cases where the trustee or trustees are UK resident they will be treated as resident for both income tax and CGT.

superseded by CG 17953r & CG 53120

Expiry of Code of Practice 10 facility in respect of Substantial Shareholdings Exemption (Schedule 7AC TCGA 1992) and introduction of a revised facility for Taper Relief (Schedule A1 TCGA 1992)

Tax Bulletin 62, issued on the 18 December 2002, detailed what to do if you (in this article, “you” means a company or individual making a Self Assessment return) wanted to know if a company was a trading company or the holding company of a trading group or subgroup for the purposes of both the Substantial Shareholding Exemption and Taper Relief. The relevant definition was enacted in Finance Act 2002.

On 21 May 2002 the Economic Secretary to the Treasury announced that, where there was genuine uncertainty, a company could seek an opinion from HMRC under Code of Practice 10 (Information and Advice) as to its trading status. Code of Practice 10 says that if there is uncertainty about HMRC’s interpretation of the law (including its application to a proposed transaction) we will advise upon the interpretation of legislation passed in the last four Finance Acts. That period (extended slightly because two Finance Acts were enacted in 2005) has now passed following Royal Assent to Finance Act 2006. Consequently from that date the facility is
no longer available.

Substantial Shareholdings Exemption (Schedule 7AC TCGA 1992)

For the purposes of the Substantial Shareholdings Exemption you may want to establish whether a company in which shares (or interest in shares or assets related to shares) were held and which you have now disposed of, was a qualifying company. In the first instance, you should seek advice from that company. The company will usually be able to tell you if its activities were such that it was a trading company, the holding company of a trading group or trading subgroup within the meaning of the legislation.

The responsibility for ascertaining the status of any company referred to in your Self Assessment Corporation Tax return (whether that is yourselves as the ‘investing company’, or the ‘company (or group) invested in’ whose shares etc. may have been disposed of) rests with you. You will need to take a view in conjunction with published guidance (currently in Tax Bulletin 62) and make your return on that basis in accordance with ordinary self-assessment principles.

Taper Relief (Schedule A1 TCGA 1992)

For Taper Relief if you want to establish whether a company in which shares were held which you have now disposed of was a qualifying company, in the first instance you should seek advice from that company. The company will usuallybe able to tell you if its activities were such that it was a trading company, or the holding company of a trading group, so that it could have been a qualifying company so far as you were concerned.

The responsibility for ascertaining the status of a company referred to in your Self-Assessment Income Tax return rests with you. Consequently you will need to take a view and make your return on that basis. (Where appropriate you may wish to point out in the white space on your return that you have made an unsuccessful approach to the company for confirmation of its status.)

However, HMRC appreciate that in some circumstances a significant number of shareholders may need to know the status of a company after making disposals of shares AND the company itself has genuine doubt as to its trading status. In such circumstances, the company may seek a post-transaction ruling from its Officer of Revenue and Customs for the assistance of the individual shareholders. Any request should be in the format prescribed in appendix 1 of Code of Practice 10. The Officer dealing with the company’s tax affairs will not be able to correspond directly with individual shareholders for reasons of confidentiality.

Any opinion that a company is or is not a trading company, or a group is or is not a trading group, can relate only to the period for which information has been made available. It is possible for a company or group to change its status at any time, as its business or activities change. Officers of Revenue and Customs will only be able to give a firm opinion on the status of a company for periods that have ended where all the relevant facts are available.

Partnerships and Certificates of Residence

The residence article in the UK’s Double Taxation Conventions (DTCs) typically provides as follows;

“For the purposes of this Convention, the term “resident of a Contracting State” means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and also includes that State and any political subdivision or local authority thereof. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.”

UK partnerships (including Scottish partnerships and UK LLPs) are not themselves liable to UK tax. Liability falls instead on the partners. While UK partners may qualify as residents of the UK for the purposes of a UK Tax Treaty, the partnership itself cannot. Accordingly, a certificate of residence cannot be issued in respect of any partnership. We have become aware that some partnerships have requested (and been given) certificates of UK residence. Clearly, this is incorrect and this article sets out what HMRC can and will do to assist UK partners to claim the benefits of the UK’s
bilateral tax treaties.

Partnerships with only UK Resident Partners

For partnerships where all partners are UK resident there should not be a problem as HMRC will, if requested, confirm that although the partnership itself cannot be UK resident the individual partners are, and are therefore entitled to the relevant Treaty benefits.

Partnerships with Non-Resident Partners

Non-resident partners are not entitled to the benefits arising from DTCs between the UK and its treaty partners because they are not persons resident in the UK as set out in Article 1 of a DTC. But, HMRC will, if requested, confirm that, although the partnership itself cannot be UK resident, the UK resident partners are entitled to the relevant Treaty benefits.

When requesting either type of confirmation from HMRC, the following details will need to be provided in writing:

a. Reason for requiring a certificate of residence;

b. The nature of the relevant transaction; and

c. Details of the income concerned. For partnerships with UK partners only, HMRC will also need:

d. A list detailing the partners’ names with confirmation that each and every partner is UK resident at the date of the request for the certificate of residence.

For partnerships with UK and non-resident partners, HMRC will also need:

e. A contact name and address for the partnership; and

f. A list detailing the partners’ names, separately identifying those that are UK resident and those that are not and confirming that each of the UK partners is UK resident at the date of the request for the certificate of residence.

Where the source state has provided a form for claiming relief from its tax on the income in question, that form should be used. The Double Taxation Relief Manual which is publicly available on the HMRC website at [DN provide link to DT manual] contains this information.

We will not confirm UK residence if we think that to do so would not be in accordance with the relevant DTC.

Miscellaneous

Review of the SP 4/86 Financial Limits for the 2006 - 07 academic year

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

Letters on any article appearing in Tax Bulletin should be sent to the Editor, Mrs Jayne Harler, Room 2C/06, 100 Parliament Street, London, SW1A 2BQ or

Statement of Practice (SP4/86) </practitioners/sop.pdf>sets out how scholarship income works when there is an employment relationship between the payer of the scholarship income and the recipient.

The financial limit contained in the SP is reviewed each year. Following this year’s review Ministers have decided that after the increase for the 2005-06 academic year, the limit for the 2006-07 will remain at £15,000.

See Statements of Practice Issued up to 31 August 2005 (PDF 1.2MB)

This was published in the ‘What’s New’ section of the HMRC Internet on 12 June 2006.

HMRC Trusts Reorganisation

We have reorganised the geographical responsibilities of our three trust offices. The reorganisation affects both existing cases and new cases. Accordingly customers may be asked to make their Self Assessment return to a different office to the one they are used to dealing with and they may receive correspondence from a different office to which they make the return.

Individual trusts affected by this have already been informed about the changes.

The revised geographical responsibilities are as follows:

  • Our Truro office will deal with trusts administered in the counties of Cornwall, Devon, Somerset, Wiltshire, Dorset and Gloucestershire represented by postcodes TR, PL, TQ, EX, TA, BS, BA, DT, GL, SP, SN and BH. It will also deal with trusts administered in the North, South, East and Central London Boroughs represented by postcodes N, E, SE, SW, W1 - W1Z, WC, EC, IG (1-6, 8, 11), RM (1-3, 5-14), EN (1-5), BR (1-7), CR, RH (1, 3, 6-10), SM, DA (5-8, 14-18), KT(1-6, 9), TW (1-14).
  • Our Edinburgh office will deal with trusts administered in Scotland and Northern Ireland, trusts established under Scottish law and trusts with corporate trustees. It will also deal with trusts administered in North East England represented by postcodes TD15, NE, SR, DH, DL and TS. Additionally it will deal with trusts administered in the West London Boroughs represented by postcodes W (2-14), NW, HA and UB.
  • Our Nottingham office will deal with trusts administered in the remaining counties of England and Wales. These include trusts administered in the London Boroughs represented by postcodes IG (7, 9, 10), RM (4, 15-20), EN (6-11), BR 8, RH (2, 4-5, 11-20), DA (1-4, 9-13), KT (7-8, 10-24), TW (15-20).

During this transition we will be working hard to maintain a high level of customer service.

HMRC Unites its business education & support teams

  • Education and support for business
  • Looking to the future

Education and support for business

From July 2006 the Business Support Teams, (former Inland Revenue), and Compliance Management teams (former Customs and Excise) will join together to offer help across all taxes to employers, businesses, international traders and individuals. The purpose of these newly integrated teams is to help our customers get their tax and national insurance obligations right, at the earliest possible opportunity.

The new teams will actively seek to support those who are more likely to make mistakes. This could include, for example, new employers and businesses or those who are facing a particularly complex tax issue for the first time.

In most cases we will make contact by letter or phone. But we will also deliver presentations and workshops to support employers and businesses in key geographical locations around the country. Where necessary, we will also provide face-to-face education on a one-to-one basis.

Our teams will provide customers with information on relevant topics, explaining how to correct any errors they may find and pointing to additional sources of help - including the events mentioned above, national telephone helplines.

We will continue to work closely with a wide range of intermediary groups. We want to take their views into account, and make sure that the advice and support we develop meets the needs of our customers.

Looking to the future

We are looking at the possibility of making some of our more straightforward workshops available by DVD or website. For more complex issues we are considering the development of a “virtual classroom” approach.

We will let you know in a later edition of this Bulletin when these products are available.

Tax Bulletin is changing so tell us what you need in future

The December 2006 edition of Tax Bulletin will be the last issue produced on paper and mailed out to you. We will not be taking subscriptions for Tax Bulletin in 2007. We will however continue to provide the level of detailed technical information currently found in Tax Bulletin on our internet site.

At the moment we can only cover urgent issues when they arise in time for the next Tax Bulletin issue. Otherwise we have to publish information through other means. We want to provide you with relevant and timely information in one place.

We envisage developing an ‘update’ service, covering hot topics from across the whole of
HMRC business and publishing the items with a limited shelf life. Items will be regularly archived
as material transfers into permanent guidance or is superseded by a further update.

We will develop this service during 2007. Initially the online product will be similar to Tax Bulletin or
Business Briefs (the current indirect tax equivalent). Over time we will develop this to meet your needs in a smarter way.

So tell us what you need from an online update service.


Room 2c/06
100 Parliament Street
London
SW1A 2BQ

Telephone: 020 7147 2317

Fax: 020 7147 0222

 

Inland Revenue Statements of Practice and Extra-Statutory Concessions issued between 1/5/06 to 30/6/06.

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.

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Article Published/Sorted/Amended on Scopulus 2006-11-02 11:31:16 in Tax Articles

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