The 2016 Budget and Finance Bill continue the onslaught against the economically productive members of society and redouble the efforts to discourage wealthy foreigners from living or investing in the United Kingdom.
A welcome reduction in the rates of Capital Gains Tax is partly counteracted by yet more rules which will convert capital gains into taxable income.
Changes are proposed to make the United Kingdom even less attractive to foreign domiciliaries.
Changes to Double Taxation Conventions and unilateral repudiation of treaty obligations will discourage non-UK businesses from dealing in United Kingdom assets.
Stamp Duty Land Tax changes will provide further disincentives to invest in homes for rental and the accusation of commercial property.
The Orwellian-named “Disguised Remuneration” rules are to be changed to create even more charges to income tax on remuneration which is not simply disguised but non-existent.
The Supreme Court has shown that it is prepared to construe taxing statutes in wholly unnatural ways if the result is to increase charges to tax.
A raft of new measures is proposed, aimed both at taxpayers and / or those who try to ensure that taxpayers pay their fair share of tax – and no more.
Robert Venables Q.C. (Chairman)
Amanda Hardy Q.C.
Philip Simpson Q.C.
All the speakers are barristers and members of Old Square Tax Chambers, 15 Old Square, Lincolns’s Inn, London WC2A 3UE.
09.00 Delegate Registration
09.30 Chairman’s Introduction
09.40 Converting Income into Capital Gains – Robert Venables Q.C. and Oliver Marre
Taking full advantage of the fall in capital gains tax rates – established anti-avoidance rules – new anti-avoidance rules proposed in Finance Act 2016, including alterations to transactions in securities rules and new rules on liquidation capital gains.
10.20 Stamp Duty Land Tax Changes – Patrick Cannon
Residential Property – Additional rate on residential property – Non-residential property
11.00 Discussion Session with Coffee
11.15 Offshore Developments – Harriet Brown
DTAs update: Jersey, Guernsey, other proposed changes and recent DTA case law •Taxation of foreign trade in UK real property •Rectification, mistake and Hastings-Bass: an offshore update • Case law update • Exchange of tax information update
11.55 The UBS Decision in the Supreme Court (March 2016) – Robert Venables Q.C.
Importance for taxation of directors and employees – A New development in the Ramsay Doctrine
12.30 Close of Morning Session
13.30 Registration for those Attending Afternoon Session Only
14.00 Chairman’s Introduction to Afternoon Session
14.05 “Disguised Remuneration” Changes – Robert Venables Q.C.
New Charges to Tax on Non-Existent Income – Finance Act 2016 Changes – Future Changes – Threatened 2019 Retrospective Tax Charge – Contractor Strategies – Close Company Profit Extraction Strategies
14.40 Promoters and Introducers & New Hurdles and Sanctions for Businesses – Setu Kamal
Recent and proposed developments in the Promoters of Tax Schemes regime – Mandatory Publication of Tax Strategies by Businesses – Rules for Businesses which Persistently Engage in Aggressive Tax Planning
15.20 Changes to Taxation of Foreign Domiciliaries – Amanda Hardy Q.C.
New Rules for Eligibility for Foreign Domiciliary Status – income tax, capital gains tax and inheritance tax – New rules for Excluded Property Trusts – New Charge on indirectly held United Kingdom Property
16.05 Discussion Session with Tea
16.20 Other Penalties and Criminal Offences – Philip Simpson Q.C.
Civil Sanctions for Enablers of Offshore Evasion – Strengthened Civil Deterrents for Offshore Evasion – The Criminalisation of Accidental Tax “Evasion” – A Duty to correct past offshore tax non-compliance – A Criminal Offence of Failing to Prevent Criminal Tax Evasion
17.00 Panel Session and Questions to Speakers
17.30 Close of Seminar
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[Posted: 23 March 2016]