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Government narrows scope of Bank Payroll Tax

Herbert Smith Freehills LLP
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United Kingdom
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December 21 2009

This year's Pre-Budget Report announced the Government's intention to introduce a one-off "Bank Payroll Tax", at the rate of 50, to the extent a company falling within the ambit of draft legislation pays a bonus in excess of £25,000

Funds post-2009 tax changes

Herbert Smith Freehills LLP
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United Kingdom
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July 3 2009

The publication of the Finance Bill 2009 marked the latest stage in a period of significant change in the UK tax treatment of investment funds and their investors

Investment trusts investing in other funds and SP397

Herbert Smith Freehills LLP
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United Kingdom
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April 21 2010

Following concerns that the conditions for approval as an investment trust company ("ITC") under section 842 of the Income and Corporation Taxes Act 1988 ("section 842") (rewritten in section 1159 of the Corporation Tax Act 2010 with effect from 1 April 2010) were not compliant with EU law, HMRC had recently indicated that it would seek to withdraw its Statement of Practice 397 ("SP397"

Change in CGT rate

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

Last year's UK Emergency Budget announced that, with effect from 23 June 2010, there would be two rates of capital gains tax (CGT): 18 for basic rate taxpayers, and 28 for higher and additional rate taxpayers

Uk tax transparent fund

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

In November 2010, the UK Government announced its intention to launch a new authorised fund regime for a tax transparent vehicle

Stamp Duty Reserve Tax (SDRT)

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

It was announced at the time of the 2010 Emergency Budget that the UK Government would consult with the industry on proposals for the reform of the SDRT 'Schedule 19' rules (investment in underlying funds

Bank payroll tax and the bank levy

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

As a sign of the current economic (and indeed political) environment, 2010 will be remembered by the UK banking sector as the year in which banks were asked to contribute a far greater share to the UK tax take

Offshore fund rules

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

Although the new UK offshore fund tax rules took effect from 1 December 2009, in reality it was during calendar year 2010 that existing offshore vehicles and vehicles coming to launch had to grapple with the new definition of an "offshore fund" for UK tax purposes

Investment trust tax and company law

Herbert Smith Freehills LLP
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United Kingdom
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January 27 2011

On 27 July 2010, the UK Government published a Consultation Document setting out proposals for the modernisation of the UK tax treatment of approved investment trust companies (ITCs