Former Tax Director, Office of Tax Simplification. Past president Chartered Institute of Taxation; formerly Head of Tax Policy, @DeloitteUK views my own
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Articles by Bill Dodwell
HMRC loses another EIS case
HMRC have just lost another tax case about their management of the Enterprise Investment Scheme. Following their loss in Ames, the First Tier Tribunal has ruled in favour of the taxpayers in Oxbotica Ltd. This is a case about the Seed EIS scheme, designed to help start-ups. Oxbotica was founded to spin out technology from Oxford University, developed by several academics.
New roles - Tax AM
After a career in private practice, I’ve just joined the Office of Tax Simplification, as a part-time policy adviser. The OTS is an independent part of the Treasury. I work in a building I’ve often visited – and now have the opportunity to get lost in. The Horse Guards Road/Parliament Street building was one of Gordon Brown’s PFI projects, which broadly coincided with bringing together Treasury and HMRC policy specialists.
More than £4 billion saved
The Treasury should be pleased by the Supreme Court’s decision in the Prudential case. The case is one of the long-running claims that the UK’s tax treatment of foreign dividends broke EU free movement of capital rules. The UK changed the law in 2009 – but there’s still plenty of money involved in claims for back years. This particular case is about portfolio dividends, typically held by investment funds, where the shareholding is less than 10% and usually much less.
“ ’in respect of’ tax avoidance”
The Upper Tribunal has upheld the First Tier Tribunal’s decision to strike out the taxpayers’ appeal on the basis it had no reasonable prospect of succeeding. The case, The First De Sales Limited Partnership (2) Twofold First Services LLP (3) Trident First Services LLP (4) Trident Second Services LLP v HMRC, concerned a tax avoidance scheme. The judgement notes “Each Appellant carried on a modest business for the purposes of which it employed one or more individuals.
Loose language - Tax AM
As impetus builds behind the BEPS Multilateral Convention, with more and more countries signing and ratifying, the question to consider is when will the new provisions apply? There are two different issues: withholding taxes on the payment of interest, dividends and royalties and provisions affecting the taxable presence, overall profit or dispute resolution rights of companies and individuals.
Commission finds mismatch in US and European laws isn’t state aid
There will be a collective sigh of relief from many UK and US multinationals at the European Commission’s ruling in favour of Luxembourg and McDonald’s. The US-parented group held intellectual property rights in a Luxembourg company, which assigned them to a US branch. The Luxembourg tax authority agreed that the income from the rights (intragroup royalties) should be allocated to the US, under the Luxembourg-US tax treaty.
Paying tax on profits
Amazon has just filed 2017 accounts for two UK businesses: Amazon UK Services, which runs its distribution centres and delivery business in the UK, and Amazon Web Services, which provides consultancy and marketing services in relation to cloud computing. The major part of Amazon’s global business is in selling goods and services; its cloud computing arm, AWS, accounts for about 10% of global sales.
Expectation created
HMRC have just lost a judicial review in relation to their guidance on VAT. Vacation Rentals provided credit card handling services and argued that they complied with the guidance set out in HMRC’s Business Brief 18/06 on when such services should be treated as exempt from VAT. HMRC later issued assessments, claiming that the services should be standard-rated.
Accounting standards are not law
The Upper Tribunal, in Ball UK Holdings has upheld the decison of the First Tier Tribunal that the company was not entitled under accounting standards to switch its financial statements to US dollars. The company was an intermediate holding company, ultimately owned by a US parent. By switching to dollars from sterling, the company claimed to crystallise a large tax-deductible loss on loans.
What next for Gift Aid?
What next for Gift Aid? © Copyright LexisNexis 2024. All rights reserved. 18 April 2024 Speed read HM Treasury is reportedly considered potential tax reforms to help boost charitable giving. The issue is being promoted by the Culture Secretary, Rt Hon Lucy Frazer, who both wishes to encourage very major donors to step forward, as well as promoting more normal donations through improvements to Gift Aid.
Tax in 2024 and beyond
Tax in 2024 and beyond © Copyright LexisNexis 2024. All rights reserved.
Nigel Lawson: the tax-reforming chancellor
© Trinity Mirror/Mirrorpix/Alamy Stock Photo Nigel Lawson was appointed chancellor of the exchequer in 1983. He delivered six Budgets from 1984 to 1989 before resigning in October 1989, following policy clashes with the prime minister. Lawson proclaimed that his 1984 Budget ‘…will be a radical, tax-reforming Budget.
What did the OTS ever do for us?
Home >Articles > What did the OTS ever do for us? What did the OTS ever do for us? 24 February 2023 Bill Dodwell looks back at the work of the Office of Tax Simplification. The announcement on 23 September 2022 of the closure of the Office of Tax Simplification came as a shock and disappointment to the OTS Board and the secretariat. I must admit I’d not included ‘government abolishing job’ in my list of personal risks....
What next for the OTS?
3 March 2022 Speed read Further to a recommendation in the recent five year HM Treasury review of the Office of Tax Simplification, the OTS has been asked to undertake a project to articulate its approach to tax simplification and clarify its aims and measures for assessing success. This review will inform how the OTS, and government, should prioritise simplification efforts over the next five years.
Committees - UK Parliament
Meeting details At 4.00pm: Private discussion Inquiry Draft Finance Bill 2021-22 At 4.15pm: Oral evidence Inquiry Draft Finance Bill 2021-22 At 5.15pm: Oral evidence Inquiry Draft Finance Bill 2021-22 Director of Policy at Association of Independent Professionals & the Self-Employed (IPSE) Policy and Advocacy Vice-Chair at Federation of Small Businesses (FSB) At 6.15pm: Private discussion Inquiry Draft Finance Bill 2021-22
The OTS: the story so far
It is widely believed that the UK is the only country which has an Office of Tax Simplification. The Office was established in 2010 on an informal basis by the Coalition Government, essentially as a Conservative initiative, following a report by former chancellor Lord Howe. It owed a great deal at the start to its first tax director and chair – John Whiting and Michael Jack, respectively – and to its main sponsor in government, tax minister David Gauke.
Committees - UK Parliament
Oct 20 2020 Tuesday 20 October 2020 Start times: 9.00am (private) 9.30am (public) Add to calendar
Buying off plan means gain taxable
The Upper Tribunal’s decision in Higgins illustrates one of the pitfalls of buying flats before they are ready for occupation. Mr Higgins agreed to buy a flat before it was constructed, signing an agreement in 2006. Building work took longer than anticipated and completion took place only in January 2010, when Mr Higgins moved into the flat. He occupied it as his main residence until he sold it in 2012.
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