- Finance Bill 2019—avoidance involving profit fragmentation arrangements
- Original news
- What is the background?
- What key changes were made to the rules since they were first published on 6 July 2018 and have the changes addressed any criticisms levelled at the previous draft of the rules?
- How much comfort can be taken from the statement in the Explanatory Notes to Schedule 4 para 2(1)(b) that: ‘A “transfer of value” for the purposes of this paragraph will not include protected foreign source income chargeable in the UK under section 731 of the Income Tax Act 2007 (ITA 2007), provided that the income has no connection with a UK business’?
- What concerns remain?
Tax analysis: Anne Healy-McAdam, tax director in the private client tax team at Pinsent Masons, considers some of the changes which have been made to the Finance Bill following the government consultation on tax avoidance involving profit fragmentation. Healy-McAdam considers that while the government has taken on board some of the stakeholder responses, the new rules will ‘continue to increase the compliance burden on individuals carrying on a business’.
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