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Revenue news

14 July 2005
Categories: News , Capital Gains , Land & property
Negligible values; International Manual; SDLT disclosure; double tax agreements

Negligible values

HMRC have accepted the following securities as having negligible value during June 2005 for the purposes of a claim under TCGA 1992, s 24(2).

Company

Security

Effective date

Snackhouse plc

ords

11.10.01

Where the value of shares has become negligible, an allowable loss may be established by the owner claiming that they are treated as being sold and reacquired, either on the date of the claim or at a specified time within the two tax years prior to the date of claim.
See www.hmrc.gov.uk/cgt/negvalist.htm for the full list of negligible value securities.

International Manual

The guidance on transfer of assets abroad (use of offshore structures) has been significantly altered and republished at International Manual INTM600000 onwards.
www.hmrc.gov.uk

SDLT disclosure

Legislation has been introduced to extend the direct tax scheme disclosure rules to stamp duty land tax with effect from 1 August 2005.
The Stamp Duty Land Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2005 (SI 2005 No 1868) describe the arrangements for stamp duty land tax that must be disclosed. These are where there is a substantial risk of tax avoidance. The Tax Avoidance Schemes (Information) (Amendment) Regulations 2005 (SI 2005 No 1869) amend the existing regulations that specify what information must be provided, and the time limits for providing it.
HMRC news release dated 11 July 2005.

DTA update

Details of the UK's plans for negotiating double tax agreements for the year to 31 March 2006 have been announced.
HMRC plan to complete work on new treaties with Botswana, the Cayman Islands, Iran, Japan and Poland. They intend to progress negotiations with China, Germany, Hungary, Hong Kong, Italy, Luxembourg, Netherlands, Saudi Arabia, Switzerland and Thailand; and also to progress negotiations with the Crown dependencies and overseas territories on tax information exchange agreements.
Exploratory talks for new or updated double taxation agreements or protocols with the Faroe Islands, Macedonia and Mexico are planned.
Representations are invited and should be sent to: Jas Sahni, Tax Treaty Team, Central Policy, HM Revenue & Customs, 100 Parliament Street, London SW1A 2BQ, e-mail: Jas.Sahni@hmrc.gsi.gov.uk.
HMRC news release dated 12 July 2005.

Faroe DTA

Discussions at official level are to be held soon about a new comprehensive double taxation agreement between the UK and the Faroe Islands. The previous agreement was terminated in 1998. Representations are invited and should be sent to: Angelia Burke, HM Revenue & Customs, Central Policy (Tax Treaty Team), 100 Parliament Street, London SW1A 2BQ.
HMRC news release dated 11 July 2005.

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