The May 2015 issue of International Client contains articles on the following:
New ‘de-offshorisation’ rules for Russia
We look at new anti-avoidance rules which were introduced in Russia with effect from 1 January 2015 to counter avoidance in relation to offshore entities.
CGT on UK residential property owned by non-UK residents
Capital gains tax has been extended to non-UK resident owners of UK residential property. The changes bring the UK into line with many other countries that charge CGT based on where a property is located. Our article considers the scope of the charge and its interaction with the Annual Tax on Enveloped Dwellings (ATED) regime.
Changes to ATED and SDLT charges for UK residential property
The ATED threshold has been reduced from £2 million to £1 million and this is set to fall to £500,000 in 2016. We outline the ATED charges and consider the reliefs available.
Social security taxes on non-French residents owning French property
France imposes social security taxes, at an aggregate rate of up to 15.5%, on non-French resident individuals with French real estate income and on capital gains realised on French real estate. Our article highlights a challenge to the application of these social security taxes.
The UK’s new diverted profits tax
We look at the application of the UK's diverted profits tax, intended to counteract arrangements by multinational groups which divert profits from the UK.
The UK’s patent box comes under increasing scrutiny
Our article outlines the UK’s favourable patent box regime, which, broadly, provides a 10% tax rate for qualifying profits from patents instead of the usual UK tax rate
of 20%. There may be a limited time for new claims to be made.