Chargeable event meaning

In this issue: VAT Taxes management and litigation Companies and corporation tax Devolution Anti-avoidance International Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information VAT Supreme Court upholds Court of Appeal’s decision that services invoiced and paid after leaving a VAT group were subject to VAT (The Prudential Assurance Company Ltd v HMRC) In [2025] UKSC 34 (The Prudential Assurance Company), the Supreme Court rejected Prudential’s appeal, affirming the Court of Appeal and Upper Tribunal (UT) that VAT was correctly payable on success fees billed by Silverfleet after it had exited Prudential’s VAT group. Although Silverfleet carried out the fund management work while both entities were within the same VAT group, the performance fees were conditional on the funds surpassing a stated threshold, which only happened after Silverfleet had left the group. The Supreme Court agreed with the Court of Appeal and the UT that Regulation...

In this issue: Budgets and Finance Bills VAT Companies and corporation tax Taxes management and litigation Employment taxes Real estate tax Energy and environment International LexTalk®Tax: a Lexis®Nexis community Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Budgets and Finance Bills The Chancellor’s Spring Forecast contained no tax announcements On 3 March 2026, the Chancellor presented the government’s Spring Forecast. As it was neither a Budget nor a significant fiscal event, no tax measures were announced in the statement. See: LNB News 03/03/2026 32... Dates scheduled for final Parliamentary stages of Finance Bill 2026 The remaining Parliamentary stages of the Finance Bill 2026 (FB 2026) are timetabled for March 2026. According to the Parliamentary calendar as currently published, the House of Commons ‘remaining stages’ are set for Wednesday 11 March 2026, with the House of Lords stages due on...

In this issue: Budgets and Finance Bills Employment taxes VAT Business structures International Companies and corporation tax Real estate tax Taxes management and litigation Devolution Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Budgets and Finance Bills Spring Statement 2025 On 26 March 2025, Rachel Reeves MP, the Chancellor of the Exchequer, unveiled the government’s Spring Statement 2025. As anticipated, and in line with the promise made at the Autumn Budget 2024, the Spring Statement 2025 was not treated as a major fiscal event. At the outset, the Chancellor restated the government’s intention to hold only one major fiscal event each year, indicating she plans to present the annual Budget in autumn 2025...

ARCHIVED This archived Practice note reviews the clawback of business investment relief (BIR), the remittance relief for investment into UK companies. It covers: extraction of value how to avoid a chargeable remittance after a potentially chargeable event the order in which disposals are treated the interaction with the mixed funds rules the capital gains tax (CGT) position STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime The Finance Act 2025 (FA 2025), which received Royal Assent on 20 March 2025, legislates to abolish the remittance basis of taxation and introduce a residence-based regime from 6 April 2025. FA 2025 also replaces domicile as the key criterion for inheritance tax liability. Additional changes include amendments to the excluded property rules, removal of protected settlements status for offshore trusts, and revisions to overseas workday relief. For details on these reforms, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based...

What is a long-term incentive plan? As set out in the Practice Note: What is a long-term incentive plan?, the awards most frequently delivered under a long-term incentive plan (LTIP) typically comprise: conditional share awards (often referred to in the US as restricted stock units (RSUs)) nil-cost options share appreciation rights (SARs) forfeitable shares, sometimes described as restricted stock A brief summary outline of the likely capital gains tax (CGT) treatment on disposals of shares obtained on the vesting of each LTIP award type is set out below. For more detail and background on the different award types available under an LTIP, see Practice Note: Structure of a long-term incentive plan—Types of awards for further guidance. Please note that this Practice Note proceeds on the basis that, at acquisition of the shares or otherwise on vesting of the LTIP awards, the employee has been fully subject to income tax and, where the shares are readily convertible, national insurance...

The Offshore bonds and other foreign policies Practice Note sets out what constitutes an offshore bond and a foreign policy, and outlines the potential tax liabilities. It also focuses on several niche topics: cluster policies (also called segmented policies), personal portfolio bonds (PPBs), the treatment of certain legacy policies, and how the foreign policy regime dovetails with the remittance basis and temporary non-residence provisions... Cluster (or segmented) policies In place of one insurance contract, certain providers supply a bundle of policies to a holder—commonly called a ‘cluster’ or ‘umbrella’ of smaller segments. Each policy, or segment, stands as a separate insurance contract. At inception every segment is the same. They may carry an identical base number with a suffix; for example, XP234567/1–100, where 1–100 denote the discrete segments. A single policy document may cover the whole cluster. UK insurers generally can offer clustered arrangements, and offshore bonds are often marketed in this way, though not every product has this feature...