The Autumn Budget 2017

This year has certainly been an interesting one in the world of tax. The Spring Budget in March produced some significant changes for non-UK domiciliaries and offshore trustees that required a lot of careful planning to be undertaken in a short period, only for the snap election to cause the proposals to be dropped, leaving a lot of people in limbo.
Many of the proposals were reintroduced after the election into a new Finance Bill, but this only received Royal Assent last Thursday despite many of the rules being effective from 6 April 2017. A mere 5 days later and we have the Autumn Budget 2017. There is only so much we can take!

The details within the Budget hold a few surprises. Firstly, from April 2019 capital gains on commercial property will be taxable on non-UK residents for the first time. We would not be surprised if indirect holdings of commercial property were also brought within the UK’s Inheritance Tax net soon, mirroring UK residential property from April 2017 - you have been warned. Secondly, following hot on the heels of the Trust Register, the Government hopes that all offshore trust structures will soon be notified to them.

Finally, where someone has made a genuine mistake in relation to anything outside the UK and wants to regularise the mistake, they will have to provide 12 years back information, rather than being able to limit this to 4, or even 6 years, where they can show the error was not the result of deliberate actions. Hopefully everyone is now 100% perfect…

The Enterprise Investment Scheme has also been tweaked slightly to help it benefit those it is really designed to help – small, early stage businesses where the risks of losing your money are significant. For those buying their first house at up to £500,000, the Stamp Duty Land Tax (SDLT) exemption will be a welcome relief from a very unsatisfying tax.

If you have any questions about how this Budget will impact you or your organisation, please speak to your usual Buzzacott contact or

Corporate indexation allowance to end
Corporate interest restrictions - amendments to the rules
Withholding tax - royalties
Intangible fixed assets - related party step-up schemes
Carried interest
Double taxation relief and permanent establishment losses
UK VAT registration threshold frozen at £85,000
VAT - Joint and several liability for online market places
Commercial Property Capital Gains Tax for non-UK residents
Non-UK resident companies and Corporation Tax
Corporate Tax and the digital economy: Cracking down on digital businesses
Impact on the tech sector

Charities & Not-for-Profits
Impact on the charity sector
UK VAT registration threshold frozen at £85,000
VAT - Refunds to combined authorities, fire and rescue authorities

Taxation of trusts
National Insurance Contributions
Enterprise Investment Scheme (EIS) allowance doubled
Property-related taxes
Benefits in kind - electric vehicles
Carried interest
Tax administration and compliance
Evasion, avoidance and compliance
Commercial Property Capital Gains Tax for non-UK residents
Non-UK resident companies and Corporation Tax
Increase to pensions lifetime allowance but little else for savers
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