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LifeTax

Saturday, 14 June 2014. HMRC have issued draft guidance. On the taxation of Tax Transparent Funds (TTF). Page 10 of the guidance deals with loan relationships and confirms that capital movements on loan relationships will be taxed on a look through basis. What the guidance does not address is the interaction of the loan relationship look through basis and TCGA 103D that treats a holding in collective ownership TTFs (CTTF) as an asset for CGT purposes, supplanting the look through basis for CGT. The PRA p...

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Saturday, 14 June 2014. HMRC have issued draft guidance. On the taxation of Tax Transparent Funds (TTF). Page 10 of the guidance deals with loan relationships and confirms that capital movements on loan relationships will be taxed on a look through basis. What the guidance does not address is the interaction of the loan relationship look through basis and TCGA 103D that treats a holding in collective ownership TTFs (CTTF) as an asset for CGT purposes, supplanting the look through basis for CGT. The PRA p...

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LifeTax | lifeassurancetax.blogspot.com Reviews

https://lifeassurancetax.blogspot.com

Saturday, 14 June 2014. HMRC have issued draft guidance. On the taxation of Tax Transparent Funds (TTF). Page 10 of the guidance deals with loan relationships and confirms that capital movements on loan relationships will be taxed on a look through basis. What the guidance does not address is the interaction of the loan relationship look through basis and TCGA 103D that treats a holding in collective ownership TTFs (CTTF) as an asset for CGT purposes, supplanting the look through basis for CGT. The PRA p...

INTERNAL PAGES

lifeassurancetax.blogspot.com

1

LifeTax: Spanish Double Taxation Treaty

http://www.lifeassurancetax.blogspot.com/2014/04/spanish-double-taxation-treaty.html

Wednesday, 23 April 2014. Spanish Double Taxation Treaty. The double taxation agreement between the UK and Spain. Comes into force from 12th June 2014. My previous post. Covered the implications of the treaty for life insurance companies with pension business. Labels: Double Taxation Agreements. Subscribe to: Post Comments (Atom). Net liability to corporation tax. Rebates of management charges. Repayment of income tax. SI 2006 / 964. Statutory instrument si 2013 2819. TCGA 1992 section 213. IFRS 9; IFRS 4.

2

LifeTax: March 2014

http://www.lifeassurancetax.blogspot.com/2014_03_01_archive.html

Friday, 28 March 2014. Finance Bill 2014 has now been published and can be found following this link:. The new legislation amending CTA 2009 465 and 490 re collective investments treated as loan relationships (see previous posts of 22 January, 4th Feb and 20th February on this topic) is at section 27 of the Finance Bill. As far as I can see the defect identified in my post of 22 January has not. Been corrected in the published legislation. Monday, 24 March 2014. My observations are as follows:. That is t...

3

LifeTax: August 2013

http://www.lifeassurancetax.blogspot.com/2013_08_01_archive.html

Saturday, 24 August 2013. No round up this week (as there's nothing much to round up.) One case that did catch my eye was the judicial review of the decision in Equity Trust Singapore Ltd v HMRC. 2012] STC 998. (More commonly referred to as the ROSIIP case.). HMRC pulled out of the case so it will not be reported but there's a good summary of what went on at. Http:/ www.rpc.co.uk/index.php? The current QROPs list includes a statement. But doesn't this means that there will be more legal disputes over QRO...

4

LifeTax: Tax Transparent Funds

http://www.lifeassurancetax.blogspot.com/2014/06/tax-transparent-funds.html

Saturday, 14 June 2014. HMRC have issued draft guidance. On the taxation of Tax Transparent Funds (TTF). Page 10 of the guidance deals with loan relationships and confirms that capital movements on loan relationships will be taxed on a look through basis. What the guidance does not address is the interaction of the loan relationship look through basis and TCGA 103D that treats a holding in collective ownership TTFs (CTTF) as an asset for CGT purposes, supplanting the look through basis for CGT.

5

LifeTax: May 2014

http://www.lifeassurancetax.blogspot.com/2014_05_01_archive.html

Thursday, 22 May 2014. ABI Guide to Good Practice for Unit Linked Funds. Further to the consultation Process. The ABI has now issued a revised guide to good practice in unit linked funds. There is however, quite a bit about documentation required and I would suggest that firms should be looking at what formal documentation they have on allowing for tax in the unit price and considering whether this meets the good practice guidance. Saturday, 17 May 2014. Solvency 2 and Deferred TAX. The PRA does not expe...

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lifeassurancetax.blogspot.com

LifeTax

Saturday, 14 June 2014. HMRC have issued draft guidance. On the taxation of Tax Transparent Funds (TTF). Page 10 of the guidance deals with loan relationships and confirms that capital movements on loan relationships will be taxed on a look through basis. What the guidance does not address is the interaction of the loan relationship look through basis and TCGA 103D that treats a holding in collective ownership TTFs (CTTF) as an asset for CGT purposes, supplanting the look through basis for CGT. The PRA p...

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