Welcome to this month’s Bite Sized.

Firstly, my thoughts and prayers go out to the people and families who were and are affected by the cowardly terrorist attack in London on Wednesday, 22 March. As the mocked up tube sign which has become the badge of resistance reads: ‘We Are Not Afraid’ and we will continue on as we did before. For anyone who hasn’t seen it, Andrew Neil’s impassioned message at the start of his BBC One programme, This Week, sums up the mood rather well.

With this in mind, I return to the world of taxation to provide you with a few updates for the month.

Annual Tax on Enveloped Dwellings (ATED) valuations

For those readers with clients who are paying the ATED charge and are using a 1 April 2012 valuation for these properties, a valuation needs to be undertaken every 5 years so a revised valuation is needed as at 1 April 2017. Please contact me if you need a revised valuation as we work closely with a certain provider who can assist you with this requirement – I would be only too happy to refer you.

Inheritance Tax (IHT) exposure on UK residential property

For those of you with clients who hold shares in non-UK ‘close’ companies which own UK residential property, these shares will no longer be excluded from IHT from 6 April 2017 onwards. A chargeable event for IHT purposes will occur on the death of the shareholder; redistribution of the share capital; certain arrangements where shares are gifted and the 10 year anniversary of a trust which holds the shares.

Budgets and backtracks…

Well well well… who dropped the ball on National Insurance Contributions (NIC)? With all of the Treasury and HMRC feasibility studies which will have been undertaken in relation to the increase in NIC for the self-employed, who would have thought that a few days later Philip Hammond scraps the rise! This is the second time Hammond has stood in front of Parliament to provide a Budget and twice I have been sat post-speech thinking, “Have I missed something here? Did he actually say anything at all?”.

If you haven’t seen it already please find enclosed a link to our Budget announcements (obviously this was drafted pre-Hammonds’ U-turn!).

Please click here for our Spring Budget 2017 summary.

Offshore Penalty Regulations – reductions for disclosure

On 9 March 2017, regulations were made which specify the amount by which an asset-based penalty may be reduced for disclosure and co-operation. These are 50% for unprompted disclosure and 20% for prompted disclosures (i.e. where HMRC find the liability rather you come forward).

Doing HMRC’s dirty work

I refer you to the obligation placed upon advisors and financial institutions to write to their clients and provide the ‘Client Notification Letter’. Please find enclosed a link to HMRC’s guidance and the letter which needs to be enclosed. If you are not aware of this requirement, please take time to review the link below because penalties may arise upon you for not taking action.

Please click here to review the guide to the Client Notification Letter.

Promotion to Partner

I am delighted to announce that Hetal Sanghvi has been made up to Partner with effect from 1 April 2017. Her hard work and dedication are always an inspiration and I welcome her to the Partnership.

Spotlight on Employment Department

Following on from last month’s focus on Intellectual Property, this month we look at Employment. The team is led by Rachel Harrap and they are a specialist team of employment lawyers who advise companies, senior executives and individuals on all contentious and non-contentious employment and partnership matters.

Kind regards

Frank Strachan
Partner | Head of Tax
For Edwin Coe LLP
d: +44 (0)20 7691 4136 | e: frank.strachan@edwincoe.com

Edwin Coe LLP is a Limited Liability Partnership, registered in England & Wales (No.OC326366). The Firm is authorised and regulated by the Solicitors Regulation Authority. A list of members of the LLP is available for inspection at our registered office address: 2 Stone Buildings, Lincoln’s Inn, London, WC2A 3TH. “Partner” denotes a member of the LLP or an employee or consultant with the equivalent standing. This guide concerns the law in England and Wales and is intended for general guidance purposes only. It is essential to take specific legal advice before taking any action.

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