Inland Revenue Tax Bulletin - Issue 49

Contents

Interpretations

Miscellaneous

(Superseded by EIM21636)

Schedule E Benefits in Kind - Calculating the cash equivalent of a benefit when there is part business use and part private use

This article deals with benefits in kind chargeable under the general benefits rules in Section 154 Income and Corporation Taxes Act (ICTA) 1988, for which the cash equivalent is calculated under Section 156. It sets out the Revenue's views:

  • on how the extension to the workplace benefit exemption, contained in this year's Finance Act and included in ICTA 1988 as S155ZA, will operate in practice.
  • on the treatment of reimbursements for, and provision of, a telephone at the employee's home.
  • about when an apportionment under Section 156(2) is appropriate when there is mixed use of the 'benefit', and when a deduction under Section 156(8) is due under the rules for expenses.
  • on the circumstances in which the decision of the House of Lords in Pepper v Hart applies to 'mixed use' benefits.

The views apply equally to Class 1A NICs. Further advice on Class 1A is in the guide, CWG5. The article does not deal with motor cars and vans available for private use, living accommodation, beneficial loans or any of the other benefits for which special rules apply. The reader should consult Booklet 480 about these matters.

Exemption for benefits provided for work purposes - Section 155ZA ICTA 1988 Introduced by Schedule 10 Finance Act 2000

Since the start of the Schedule E benefits legislation in 1948, there has been an exemption for the benefit

'in premises occupied by the employer ... of accommodation, supplies and services used by the employee solely in performing the duties of the employment.'

The need for this exemption demonstrates the scope of Section 154(1), which brings to charge 'benefits or facilities of whatsoever nature'. Without the exemption desks, chairs, telephones, photocopiers, computers and all the usual office equipment would have to be reported on a P11D with the employee making an expenses claim for work use, or a dispensation sought.

This year's Finance Act extends the exemption to situations where

'any use of (the benefit) for private purposes by the employee ... is not significant.'

Exemption is also allowed for benefits provided other than on the employer's premises provided that private use is not significant and

'the sole purpose of providing the benefit is to enable the employee to perform the duties of his employment.'

These changes recognise that employers face practical difficulty in policing the 'solely' test, and that working practices have changed since 1948. It is now relatively common for office equipment to be supplied for work use other than on the employer's premises.

'Not significant' private use has not been statutorily defined. It will depend on all the circumstances of the case but an important factor will be the employer's policy for allowing employees to make occasional private use of work items. Employers will not be expected to keep detailed records of every instance of actual use in order to substantiate a claim for exemption. If the employer's policy is:

  • clearly stated to the employees and sets out the circumstances in which occasional private use may be made, and
  • any policy of the employer not to recover the costs of such private use is a commercial decision because the administrative costs of doing so would exceed the amounts involved, rather than a desire to reward the employee, and
  • there are reasonable checks to ensure that the policy is actually followed in practice

then provided that the amount of private use is small compared to work use, we will accept that the test is met.

Some benefits are excluded from the possibility of exemption. These are motor vehicles, boats, aeroplanes and benefits which involve improvements to living accommodation or any structure on land adjacent to and enjoyed with such accommodation. Such benefits must continue to be reported on form P11D whatever the extent of 'business' use of the benefit by the recipient. A deduction from the reportable amount, in respect of the use of the benefit by the employee in performing his duties, may be due. If the employee completes a Self Assessment tax return, the deduction should be made on that return.

Telephones

An employer may pay for or provide a telephone line in an employee's home so that the employee may make outgoing and receive incoming calls for work purposes.

Employer pays towards or reimburses the cost of an employee's home telephone.

If the employer pays a cash allowance towards, or reimburses the employee's telephone costs, then the amount paid or reimbursed is chargeable to tax and the employee may get a deduction under the expenses rules for the actual cost of calls made in the course of the duties of the employment. Class 1 National Insurance Contributions are payable on the amount paid by the employer towards the cost of the rental and all private calls.

Employer is the subscriber for the telephone line and responsible for paying the telephone bill.

If the benefit to the employee of the employer providing the telephone is not exempt from income tax (see below), then the employee is chargeable to tax on the expense incurred by the employer (the cost of the line rental and the cost of all calls) less any sum that the employee may make good to the employer for, say, private use of the telephone. The employee may get a deduction under the expenses rules for the actual cost of calls made in the course of the duties of the employment. Class 1A National Insurance Contributions are payable by the employer on the cost of the line rental, and, unless the cost of private calls are made good by the employee, the cost of the calls.

The benefit of the telephone line will be exempt from tax, and from Class 1A National Insurance contributions if:

The employer's sole purpose in providing the telephone is to enable the employee to perform their duties, and

the employee's private use of the benefit of the telephone is not significant.

The exemption will apply where:

  • there is a clear business need for the employer to provide the employee with a telephone, and
  • the employer has internal controls to monitor, control and minimise the cost to him/her of private use, and
  • the employer has no intention to reward the employee.

Examples where the exemption is likely to apply include cases where an employer provides a telephone line so that employee may make or receive calls which are a vital and central part of the duties of the employment, such as:

ministers of religion, where there is an imperative need for contact with their parishioners and congregations 24 hours a day.

teleworkers, where a telephone line at home is provided for remote computer working or telephone business.

employees such as care workers in residential homes for the elderly, or disabled, or hospices, whose daily duties may require contact with the emergency services or contacting relatives of those they care for.

Relief for telephone line rental

Section 198 ICTA 1988 permits relief for qualifying travelling expenses and for other expenses that are incurred wholly, exclusively and necessarily in carrying out the duties of a person's employment. The decision in Lucas v Cattell (48TC353) denied a claim for relief for telephone line rental for a telephone installed in an employee's home where the telephone was available for private use as well as for use in carrying out the duties of the employment.

In practice the Inland Revenue has allowed relief for a proportion of telephone line rental in certain defined circumstances set out in the old SE Manual at SE4331. These are cases in which there is a clear business need to have a telephone available to carry out the duties of the employment, for example where it is genuinely part of someone's duties to deal with emergencies. The extension of Section 155ZA, described above, now covers this sort of situation by providing exemption from the benefit charge where an employer provides a telephone line and all the relevant conditions are met. In view of this reform, we intend to discontinue the practice at SE4331. Relief will still be available for the actual cost of business calls.

We recognise that there may be some employees who have organised their affairs on the assumption that the practice at SE4331 would continue to apply. For that reason the practice will not be withdrawn until 5 April 2001.

Apportionment under Section 156(2) and deduction under Section 156(8)

Section 156(2) allows for apportionment if the employer's expense in or in connection with providing a benefit for an employee relates partly to the benefit and partly to 'other matters'. This will apply if, for instance, the asset or service comprising the benefit is used in the employer's business in a way other than as the provision of a benefit for the employee. In deciding whether this is so then, unless the statutory context indicates otherwise (as used to be the case with mobile telephones, where the tax charge related to provision of the 'phone for private use), provision for use by the employee in performing his or her duties is just as much a benefit within Section 154 as provision for the employee's private use. The employee's avenue of relief for use in performing the duties of employment is by deduction under Section 156(8), not apportionment under Section 156(2). If there is an 'other matter' which calls for a proper apportionment, Section 156(2) works by reducing the chargeable cash equivalent of the benefit.

Section 156(8) allows for a deduction, from the chargeable cash equivalent of a benefit, for:

qualifying travel expenses and other expenses that are incurred wholly, exclusively and necessarily in the course of the duties of the employment (Section 198), and for other matters treated as falling within Section 198 (for instance expenses within Section 193(3))

  • professional subscriptions (Section 201)))
  • directors' and officers' liabilities (Section 201AA)
  • expenses deductible by ministers of religion (Section 332(3)).

Any relief due is given by deduction from the chargeable cash equivalent. Unless such relief has been taken into account in a dispensation (if it fully matches the chargeable benefit) the benefit should be reported by the employer on form P11D. The employee gets relief due under Section 156(8) by claiming a deduction, usually on his/her Self Assessment tax return.

Class 1A National Insurance Contributions are payable on the chargeable cash equivalent of the benefit before any deduction is made under Section 156(8). The one exception to this is if the deduction due under Section 156(8) fully matches the chargeable cash equivalent of the benefit. If that is the case no Class 1A is payable, even though the benefit concerned may not have been included in a dispensation.

Pepper v Hart and mixed use benefits

The House of Lords decision in Pepper v Hart 65TC420 (that the expense of providing a benefit was the marginal additional expense of its provision) was based on the opening words of what is now Section 156(2) 'the amount of any expense in or in connection with' the provision of a benefit. Our view is that the decision also applies to the similar words in Section 156(5)(b). So if the employer's sole motive for the purchase and continued ownership of an asset is for use it in its business, other than by provision as a benefit to an employee or employees, and the exemption in Section 155ZA does not apply for any reason, the Pepper v Hart marginal additional cost principle will apply to 'running' expenses within Section 156(5)(b). The chargeable cash equivalent of the benefit for an employee to whom the asset is provided will therefore be a proper proportion of its annual value plus the marginal additional running expenses relating to its provision as a benefit. This is the amount that the employer should report on form P11D. If the employee uses the benefit, in whole or in part, in circumstances which attract relief under Section 156(8), any relief due should usually be claimed on his/her Self Assessment tax return.

New Criminal Offence for Tax Fraud

Introduction

Section 144 of Finance Act (FA) 2000 introduces a specific criminal offence aimed at tax fraud and punishable by up to seven years in prison. This fits with the Chancellor's commitment in his Budget Speech to implement the recommendations of the review of the informal economy he asked Lord Grabiner QC to undertake last November.

Lord Grabiner considered that at present we concentrate too much on prosecuting the largest frauds to the exclusion of smaller, but still serious, tax frauds. To address this point fifty extra staff will be drafted into Special Compliance Office ('SCO') to join existing criminal investigators there. As at present, local office staff will not carry out criminal investigations.

The Grabiner report made some further recommendations:

  • That there should be more joint investigations involving the Benefits Agency, HM Customs and Excise and the Revenue. He singled out as a particular target, so called 'collusive employers'. That is employers who evade the tax due under PAYE and national insurance contributions (and sometimes VAT), by paying their work-force wholly or partly in unrecorded cash; at the same time employees are encouraged to claim income-related benefits (and tax credits) on the strength of their understated earnings.
  • That there should be a confidential helpline for advice on putting tax and benefits affairs in order. This can be reached on 0845 608 6000.

Features of new offence

The new offence is to be "knowingly concerned in the fraudulent evasion of income tax". The detail of the new offence reflects its genesis in the Grabiner review in several respects:

  • It applies only to the fraudulent evasion of income tax; that was the particular area of tax fraud on which the review concentrated.
  • It can be tried either summarily or before a jury. That is a feature of similarly worded offences concerned with VAT and NIC fraud and of the general law offences the Benefits Agency uses in serious cases. Lord Grabiner considered the absence of a suitable 'either way' offence as a hindrance to the change in our approach he recommended. It will not be for the Revenue to decide on the mode of trial.
  • It applies to offences committed from the beginning of 2001; participants in the informal economy are therefore given the opportunity to regularise their affairs under current law and practice.

Conduct amounting to the new offence

In general and subject to the point about Scots law below, the new offence does not criminalise conduct which is not already an offence under current law. Case-law suggests that the ambit of the new offence is similar to that of the existing common law offence in England and Wales of cheating the public revenue, an offence used for the prosecution of many existing income tax frauds. (But, as Lord Grabiner noted, 'cheat' cannot be tried summarily, unlike other offences which often go hand in hand with tax and contribution frauds.)

Dishonesty

Dishonesty is a necessary feature of conduct which can amount to an offence under a number of provisions relevant to fraud in the widest sense. But dishonesty is the very essence of 'cheat' and will be for the new offence. The criminal courts have never sought to define as such the conduct which counts as dishonest but they have provided guidance which is likely to apply in this context (1). Conduct is dishonest if:

(1) The leading case is Ghosh - [1982] QB 1053

  • by the ordinary standards of reasonable and honest people it is dishonest; and
  • the person whose conduct is under consideration must have realised that the conduct was dishonest by those standards.

A positive act of deception (such as completing a tax return known to be false) is not a necessary element either of 'cheat' or of the new offence. Deliberately refraining from notifying chargeability to tax or from submitting tax returns, in circumstances where the person concerned must have known tax should be paid, may well in itself amount to dishonest conduct and therefore to either offence.

The new offence, unlike 'cheat', applies to offences committed in Scotland as well as elsewhere in the United Kingdom. Under current Scottish law, however, there is no precise equivalent of 'cheat'. The nearest, the Scottish common law offence of 'fraud', requires some positive act of deception. So the new offence does entail an extension in the conduct which counts as criminal north of the border.

'Knowingly concerned' in an income tax fraud

During the debate in the Finance Bill Standing Committee, the Paymaster General was asked in what circumstances a customer of a business could become 'knowingly concerned' in a fraud by that business. She explained that the test was one requiring both knowledge (rather than mere suspicion) of an offence and also actual involvement in it. Simply paying for services in cash was unlikely to satisfy this test.

The borderline between avoidance and evasion

In the same debate at least one Member raised the subject of the impact of the new offence on tax advisers, especially those involved in advising on arrangements which could be characterised as tax avoidance. We do not consider that the new offence has led to any change in the law in this area.

Where a scheme labelled as 'avoidance' by its participants and their advisers admittedly fails, the key issue as a matter of criminal law would be whether they have been dishonest in the unsuccessful effort to reduce the relevant tax liability. It would be for the courts to decide as a question of fact whether that is the case.

Concern has been expressed in some quarters that as a result the decision will not normally be taken by those with professional experience of tax matters and, given the highly technical nature of much tax law, that state of affairs may lead to injustice. That is an issue well beyond the scope of this article, but it may be helpful to remember that possible dishonesty becomes a consideration in this context only in certain circumstances. That is where there is some suggestion that the participants in an avoidance scheme are not merely relying on the intrinsic technical soundness of the arrangements actually put in place to reduce the liability, but also on concealment of the true facts from the inspector. If so, then, if the scheme fails, it is perfectly possible that the criminal courts may find there has been an offence. But, conversely, where there is no trace of any concealment of the true facts of arrangements for which there is a respectable technical case, it is hard to imagine how a criminal offence can have been committed.

Finance Act 2000 - Section 97 and Schedule 27 Modernisation of group relief

The changes to the group relief rules in this year's Finance Act allow groups and consortia to be established for group relief purposes through companies resident anywhere in the world. Group relief has also been extended to UK branches of non-resident companies, and the rules for the surrender of losses attributable to overseas branches of UK-resident companies have been brought into line.

The new rules apply for accounting periods ending on or after 1 April 2000. But periods straddling 1 April will be apportioned so that the changes take effect only in respect of losses arising from that date.

Companies and their advisers may find it helpful, in submitting claims for group relief, to have some guidance on the operation of the new Sections 403D and 403E Income and Corporation Taxes Act (ICTA) 1988, which contain the rules for branch losses. The following summary outlines the basic principles of these new rules and gives examples of how they will apply in practice.

These examples represent the Revenue's current understanding of the law in the various countries mentioned but should not be taken as definitive statements on the foreign law. It was not possible in the time available to check each statement with the relevant overseas fiscal authorities.

Section 403D - losses of UK branches of non-resident companies

New Section 403D allows for the surrender of losses of UK branches, but not where that loss is deductible or allowable, in any period, against non-UK profits (i.e. profits outside the scope of UK corporation tax) of that or another person for the purposes of any foreign tax. The purpose of the rule is to prevent relief being obtained twice - once for UK tax and once for overseas tax.

Companies in territories which operate a credit system in relation to UK branch income and which allow UK branch losses to reduce the total profits taxable will generally not be able to surrender losses. This will still apply where the overseas company also makes a loss on its domestic activities as long as the total loss is, as in the UK system, available to carry forward against future profits. Only where it is clear at the time of the claim that the loss can never be used (e.g. because the company is in liquidation and any possibility of an overseas form of group relief has been ruled out), will the UK branch loss be available for surrender. It is not sufficient that relief available overseas is not in fact claimed.

Countries which operate a credit system for UK branch profits and which allow UK branch losses to reduce non UK profits include Finland, Denmark, Norway, Sweden, Spain, Italy, Austria, USA, Ireland, Canada (other than for companies carrying on life assurance business, where an exemption system operates) and New Zealand. (Some of these countries may apply an exemption system to profits or losses arising through branches in territories other than the UK depending on the terms of the treaty between the two countries.)

Group relief is available where the company is resident in an exemption territory, but only where the loss arising in the permanent establishment cannot be set against other profits (whether or not it is recouped at a later date).

In France a loss in a UK permanent establishment cannot be relieved against French taxable profits unless (a) the company has elected to join one of the consolidation systems and calculates its tax base by including the results of foreign operations or (b) the company benefits from the special provision for overseas investment, whereby a provision equal to the first four years of branch tax losses is relievable against the company's other profits. Where neither of the above applies group relief is available.

Although the Netherlands operates an exemption system, losses of overseas permanent establishments are nevertheless available for set-off against domestic income of the company after being set first against non-taxable foreign source income. If the loss in the UK branch is entirely set against such non-taxable income in the Netherlands, group relief will be available in the UK. However, if the loss in the UK branch is available against domestic income (i.e. it exceeds profits in other foreign branches) group relief is not due.

While Switzerland does not tax foreign profits it allows branch losses against domestic profits. Under both the Dutch and Swiss systems the tax relieved may eventually be recouped when the branch becomes profitable, but that will not make the losses available for UK group relief. In Switzerland a company can claim a lower rate on domestic income in lieu of deducting branch losses. A company that has elected to be taxed under that particular system can surrender the losses of its UK branch as group relief.

Although profits arising through a UK permanent establishment of a German company are exempt from German tax, any losses arising are deductible from the company's profits (as long as the branch is engaged exclusively in the active conduct of a business). Any loss which is relievable in this way is not available for UK group relief. The fact that the losses must be recouped when the permanent establishment subsequently realises profits does not affect the position.

Under Australian law losses in UK permanent establishments are not relievable against other income, so UK group relief is available.

Luxembourg neither taxes UK branch profits nor allows losses. Belgium does not tax UK branch profits but allows losses against taxable income after they have been set first against other non-taxable foreign income. Group relief will therefore be available for Luxembourg companies, but for Belgian companies it will only be available where no part of the loss is, or ever can be, set against taxable sources of income in Belgium.

Under US law a company is taxed on its world-wide income and cannot therefore make a UK group relief claim on branch losses. Where, however, a US group has elected to make a consolidated return, a branch loss cannot be consolidated into the return if the company is permitted to use those losses elsewhere. The effect of the tie-breaker at Section 403D(6) is that, where deductibility of a loss overseas depends on whether the loss is deductible in the UK, the loss is treated as deductible overseas. So the loss is not available for surrender as group relief. This is in line with the internationally recognised principle that the country of residence has primary responsibility for relieving losses.

Section 403E - overseas branches of UK-resident companies

New Section 403E acts as a mirror provision to Section 403D. A UK-resident company trading through an overseas branch cannot claim group relief on that part of the loss that arises in the branch if it is deductible or otherwise allowable against the non-UK profits of another person. We are aware of only a few countries which do allow relief for the losses of the branch of a non-resident company against the profits of resident companies.

In applying Section 403E, the question of whether the losses will be relievable overseas will be decided without hypothesising entities and structures which do not exist at the time of the claim. So, for example, where an overseas country allows the losses of a branch to be carried forward when the branch is incorporated, that will not prevent the losses from being surrendered as group relief if the branch has not in fact been incorporated.

Ireland allows a relief similar to UK group relief for branches of non-resident companies, and as in the UK that relief cannot be carried forward. So where there are group members resident in Ireland which have profits for the year in which a claim can be made, the branch loss will not be available for surrender in the UK.

Where a French group has elected to be taxed under a consolidation system which allows losses in French branches of UK subsidiaries to be offset against group profits (of that period or a later one), that part of the UK company's loss that arises in France must be excluded from the UK group relief claim.

Where a German Organschaftincludes the German branch of a UK company, no UK group relief will be available for any loss attributable to the branch.

UK group relief will also be restricted where a UK company is a member of a loss-making partnership trading in a territory where that partnership is treated as a corporate body (for example, an Australian or US limited partnership) and within local group relief provisions.

! This Article Is No Longer Current (Deleted Index 2001)

Offshore manning arrangements for mariners

Introduction

This article on National Insurance Contributions (NICs) in respect of the employment of mariners:

  • follows up on the commitment (1) given by the Government in December 1998, and
  • looks at the interaction between tonnage tax and offshore manning arrangements for ship operators.

(1) The strategy paper - British Shipping - Charting a New Coursewas published in December 1998 by the Department of the Environment, Transport and the Regions (DETR) and, at paragraph 104, gave a Government commitment, to " publish clear guidelines for the industry and unions on the applicability and use of offshore contracts for seafarers".

The terms "mariner" (used in National Insurance legislation) and "seafarer" (used in tax legislation) are treated as interchangeable.

The Policy Background

In Charting a New Course the Government recognised that

"One significant cost element in European employment is the 'social charge' levied by governments. In the UK, this takes the form of the employers' National Insurance (NI) contribution... Reduction (to zero) of employers' social charges in respect of seafarers is permitted under the EU maritime state aid guidelines and many other European countries provide some form of alleviation." (Paragraph 102)

"The UK shipping industry has long sought similar alleviation. The British Government, however, has always taken the view that exception on a sectoral basis is irreconcilable with the principle of universality (of cost and benefit) on which the NI scheme operates." (Paragraph 103)

In recent years the UK shipping industry has transferred significant numbers of employment contracts either to non UK members of shipping groups or unconnected offshore employers (offshore manning arrangements) in order to remain competitive with operators in other jurisdictions. Uncertainty about the application of the NICs rules to such offshore manning arrangements led to the Government commitment given in paragraph 104 of " Charting a New Course".

Assumptions

For the purposes of the article it is assumed that:

  • the employee mariner is liable to primary NICs;
  • Council Regulation (EEC) 1408/71 does not apply;
  • no Double Contributions Convention with another country applies to override United Kingdom National Insurance law.

Although different legislative references apply in Northern Ireland, there is no difference between that legislation and Great Britain legislation on mariners.

Special legislation for Mariners

Liability to primary (employee) contributions is normally based on the presence, residence or ordinary residence in the UK of the employee who works in the UK. Liability for secondary (employer) contributions is normally based on the employer being resident in or having a place of business in the UK. Mariners could be excluded from the contribution scheme because of the nature of their employment and hence from access to benefits if their particular circumstances were not considered.

For mariners and their employers, regulations 86 to 96 inclusive of the Social Security (Contributions) Regulations 1979 (SI 1979/591) ('SSCR'), give effect to the policy objective of successive Governments to protect the benefit entitlement of mariners by extending their ability to pay contributions beyond the shores of the UK in certain circumstances. These 'mariners regulations' are described more fully below.

Section 7 Social Security Contributions and Benefits Act 1992 ('SSCBA') defines a secondary contributor as the employer. "Employer" is further defined in the 1979 Regulations as any person paying emoluments (paragraph 2(1) Schedule 1 of 1979/591).

A material condition for secondary liability in the general rule is that the employer has a "place of business" in the UK, but this is not defined in legislation.

However "employer" is not specifically defined in the mariners regulations so there is an argument that it might have a less restricted meaning. It is thought likely that the Courts would take into account any definitions elsewhere in the Act or regulations and accordingly the Inland Revenue treats the meaning as applying generally unless specifically legislated.

Regulation 86 gives definitions of expressions used such as "mariner" and "ship".

Regulation 93 prescribes that, where the employer is not resident and does not have a place of business in the UK, the secondary contributor is deemed to be the person paying the emoluments, whether or not payment is made as agent for the employer, provided that he/she satisfies regulation 87.

Regulation 87(1)(a) disapplies the provisions in regulation 119 onwards relating to residence and other requirements of contributors. The regulation goes on to set out the residence and domicile rules, which apply instead for mariners and their employers - the secondary contributor. Under regulation 87(1)(c) it is a condition of liability to pay a secondary contribution that the secondary contributor is resident or has a place of business in the UK.

Regulation 88 treats a mariner's employment as "employed earner's employment", and therefore liable to Class 1 primary and secondary contributions, even though it might not normally be such an employment within Section 2 SSCBA. The mariner still has to satisfy residence requirements. The employment of a mariner on a British ship will always be, or treated as, employed earner's employment. On other ships the position will depend upon the specific facts. The regulation includes circumstances such as employment on board British ships, contracts entered into both in and outside the UK and different types of mariner. And depending on the situation covered within the regulation, the owner, employer or the person paying the emoluments has to have a place, or principal place, of business in the UK.

Although this article does not concern itself with Double Contribution Conventions ('Reciprocal Agreements') the Revenue is aware that a popular base for offshore manning arrangements is Guernsey. The effect of the reciprocal agreement with Guernsey, if it needs to be considered, is that mariners on a British ship and ordinarily resident in the UK come within the mariners regulations noted previously. Queries about reciprocal agreements with other countries should be addressed to Personal Tax Division at the address noted at the end of this article.

Applying the legislation to offshore contracts

Under the mariners regulations, there cannot be any liability for secondary contributions if the employer (and, if different, the person paying the emoluments to the mariner) is not resident or does not have a place of business in the UK.

It is also important to mention that the mariner in these circumstances is not stopped from paying over the primary contributions if the secondary contributor does not voluntarily pay over the primary contributions. The mariner's contributory benefit entitlement is thereby protected. It is our expectation that most employers in this sector voluntarily pay over the primary liability even if there is no secondary liability.

Place of business in UK

We would normally accept as a strong indication that there is a place of business in the UK if a company is registered under the Companies Act 1985. But whether there is a place of business in the UK is a question of fact based on the individual case. Case law has shown that a company establishes a place of business in the UK if it carries on part of its business here. Such business activity need not be either a substantial part of, or more than incidental to, its main objects ( South India Shipping Corporation Ltd v Export-Import Bank of Korea [1985] 2 AER 219). However there must be a more or less permanent location, not necessarily owned or leased by the company but associated with the company, from which its business is conducted habitually or with some degree of regularity ( Re Oriel Ltd [1985] 3 AER 216). In Canadian law the premises of a group company are not sufficient in themselves to be a place of business for another group member ( Imperial Oil v Oil Workers International 69 WWR 702).

We would not seek to claim in isolation that there is a place of business where the overseas provider legally, and in exchange for a payment commensurate with the service, sub-contracts services to a UK business. And similarly we would also not normally attempt to claim in isolation that the unconnected UK business is the employer if it is genuinely not paying the mariners directly.

Evidence of employment

We would expect that the non-UK employer has evidence of:

  • legally binding contracts with the employees,
  • agreements with the shipping unions (if appropriate),
  • disciplinary agreements, proper payroll procedures,
  • liability for payment of earnings and tax liabilities if the ship owner or cruise operator were to default on the fees due to the employer,
  • employers' liability insurance.

It is always open to the Inland Revenue to check the reality of any arrangements, or clauses therein, are not part of sham arrangements or are not part of a composite scheme entered into solely to avoid NIC and capable of being challenged under the Ramsay principle. The practical effect of the above is that we would normally accept that the overseas employer, whether another group company or a third party employer, is the employer if legally the contracts of employment are held by it.

For completeness, it is worth mentioning the "agency regulations" in the Social Security (Categorisation of Earners) Regulations 1978, whereby the agency is treated as the employer in defined circumstances. However they cannot apply, even if the mariners' regulations could be ignored, because the agency regulations only affect workers who are not already employees of the agency or the client.

Transfer pricing

If the overseas manning arrangements of a UK ship operator are undertaken by a related party, the normal transfer pricing rules will apply to any transactions between them. Where the related overseas manning company is also a controlled foreign company (CFC), then the transfer pricing legislation may apply to the computation of the CFC's profits.

Tonnage tax

A qualifying company for tonnage tax purposes must operate ships which " are strategically and commercially managed in the United Kingdom" (paragraph 16(1)(c) Schedule 22 Finance Act 2000). This phrase comes from European guidelines on State Aid and is not defined in UK law.

The Inland Revenue has set out its interpretation in Statement of Practice 4/2000, where it has listed a "basket" of activities reflecting certain elements of management. Personnel management is on that list so a UK ship operator using an overseas manning company would have to demonstrate sufficient other significant factors from the list in order to satisfy the strategic and commercial management test. The absence of any manning activity undertaken in the UK will not be fatal to the company or group qualifying for tonnage tax, provided that there are sufficient other elements of management activity present in the UK.

The Inland Revenue would expect to discuss this issue with a taxpayer during the clearance procedure preceding an election for tonnage tax.

Summary

The Inland Revenue:

  • will expect offshore manning agreements to be genuine commercial arrangements where the overseas employer can demonstrate all the usual evidence of employment of the mariners, unless so devoid of commercial purpose as to be capable of being challenged under the Ramsay principle,
  • accepts that such bona fidearrangements, where neither the employer nor the payer of the mariners is resident in the UK and neither have a place of business in the UK, will not create a liability to employers' secondary NICs; and
  • does not believe that such arrangements will prevent strategic and commercial management of ships being carried out in the UK, for the purposes of tonnage tax, provided that the company can demonstrate a sufficient weight of other activities remaining in the UK.

Further information

National Insurance Contributions
Steve Hickson
Personal Tax Division
Room 75E
Benton Park View
Longbenton
Newcastle Upon Tyne
NE98 1

Tel: 0191 225 6029
Fax: 0191 225 7029
E-mail: Steve.Hickson@ir.gsi.gov.uk

Tonnage Tax
Michael Staples
City F Large Business Office
Ibex House
Minories
London
EC3N 1HL

Tel: 020 7265 5366
Fax: 020 7265 5302
E-mail: Michael.Staples@ir.gsi.gov.uk

! This Article Is No Longer Current (Deleted Index 2001)

Centre for Non Residents

As part of the Inland Revenue's drive to provide a better and more responsive service to its customers, a new office specialising in the taxation of non-residents is being launched on 1 April 2001. The Centre for Non-Residents will handle operational and technical work (including compliance) relating to non-resident individuals, non-resident-trusts and certain non-resident companies. It will operate and provide advice on all aspects of the Non-Resident Landlords Scheme, handle claims and applications for relief by all non-residents under double taxation agreements, provide advice on the residence and domicile status of individuals, and have responsibility for the operation of Section 739 ICTA 1988 (transfer of assets abroad).

The Centre for Non-Residents aims to provide a quality one-stop service to non-residents and their agents. More information regarding the services to be provided will follow before April.

Please let us have your views as to how best the CNR can serve its customers. Comments and suggestions are very welcome and should be sent to:

Roger Willoughby
Room 107
St John's House
Merton Road
Bootle
Merseyside
L69 9BB

Interpretations

Section 765 ICTA 88

Section 765 requires UK companies with overseas subsidiaries to obtain the consent of the Treasury before certain transactions involving those subsidiaries are carried out.

Consent may be given specially or generally. For the former, application must be made to the Treasury. For the latter no application is necessary and the transactions to which consent is given generally are described in the "The Treasury Consents 1988".

The Treasury General Consents adapt certain definitions used elsewhere in the Taxes Acts, including the definition of a group for group relief purposes. As a result of changes in Finance Act 2000 to the definition of group for group relief purposes, a number of changes have been made to the definitions of groups for the purposes of the Treasury General Consents. For transactions carried out on or after 28 July 2000:

"Overseas group" means

"Two or more companies, including the non-resident company, which are not resident in the United Kingdom and which -

a) are liable to tax in the same territory outside the United Kingdom by reason of domicile, residence or place of management, and

b) would be deemed to be members of a group of companies for the purposes of Chapter IV of Part X of the Income and Corporation Taxes Act 1988".

"Territorial Group" means

"Two or more companies which are not resident in the United Kingdom and which -

a) are liable to tax in the same territory outside the United Kingdom by reason of domicile, residence or place of management, and

b) would be deemed to be members of a group of companies for the purposes of Chapter IV of Part X of the Income and Corporation Taxes Act 1998".

"Resident Group" means

"Those companies, including the resident company, which are resident in the United Kingdom and which are deemed to be members of a group of companies for the purposes of Chapter IV of Part X of the Income and Corporation Taxes Act 1988".

Additionally, reference to "Section 258 of the Taxes Act" at paragraph 2(3) of the Treasury General Consents 1988 is now a reference to "Chapter IV of Part X of the Income and Corporation Taxes Act 1988".

Full details were included in an Inland Revenue news release on 28 July 2000.

Miscellaneous

Pension Scheme Office publications

Since the last summary in Tax Bulletin Issue 44 (December 1999) the PSO has issued 14 Updates, as listed below. Starting with PSO Update 59, Updates are now available on the PSO's pages of the IR Website www.inlandrevenue.gov.uk under 'Leaflets and Booklets'

The Practice Notes (IR12) manual was posted on the Web site in March and a selection of Frequently Asked Questions went on at the end of August.

PSO'S Web Content

Practice Notes (IR12 1997)
PP Guidance Notes (IR76 1999)
PSO Updates 59 onwards
Frequently Asked Questions
Personal Pensions (leaflet IR78)
You and the Pension Schemes Office (leaflet COP1)
Occupational Pension Schemes (leaflet IR129)
How to complain about the Inland Revenue and the Valuation Office Agency (AO1)
Occupational Pension Schemes. A guide for members of Tax Approved Schemes. (PSO1)
Application forms

PSO Updates

Update 58 - 28 January 2000

Customer Service
This was the last of the old style Updates combining:

Mailing List Subscription
Personal Pension Guidance Notes (IR76)
Faxes
Applications for Approval
Personal Pensions Helpline
Urgent letters
Revised Form 1(SF)
Adjudicator's Report
Exchange
New Customer Service Manager
Replacement Pages to PN (paragraphs 16.54-16.90)

Update 59 - 28 January 2000

Compensation Payments Directed by the Pensions Ombudsman
Previously, approved schemes could not normally pay compensation out of approved funds. This update explained how schemes would now be able to have rules that would make such payments possible. The payments would be treated as a 'scheme expense', providing those payments were directed by the Pensions Ombudsman

Update 60 - 10 February 2000

Introduction of Pension Sharing on Divorce
Proposed timetable for the introduction of Pension Sharing on Divorce.

Update 61 - 10 February 2000

PSO Updates: New Format
This set out the intention and style of the new look PSO Updates.

Update 62 - 28 April 2000

Pensions Sharing on Divorce or Nullity
Explanation of changes to tax law and Inland Revenue practice to allow pension sharing in tax approved pension schemes.

Tax approved pension schemes must take the necessary steps to enable them to comply with pension sharing orders. Similarly, buy-out contracts and retirement annuity contracts will require policy endorsements, so that pension sharing can take place.

Update 63 - 16 June 2000

SSAS 5 Year Annuity Purchase Deferral
Small Self Administered Schemes (SSASs) with a 5 year annuity purchase deferral rule were to immediately observe the same restrictions on certain investments and borrowing that applied to schemes which permit annuity purchase deferral up to age 75. Rule amendments were to follow.

Update 64 - 16 June 2000

Occupational and Personal Pension Schemes: Rebated and Shared Insurance Commission
Referring to PSO Update No 33, this stated that it is a requirement of approval that a commission/reward which emerges:
    • as a result of the direct or indirect movement of funds from one investment vehicle to another, and
    • which is rebated by an intermediary to the client or paid direct to the customer,

must be retained within the scheme and utilised in accordance with its trust deed and rules.

This makes it clear that the above requirement includes transactions such as annuity purchases.

Update 65 - 16 June 2000

Customer Service
Covering:

Improved Response Target
New Quality Target
Improved Approval Target
Business by Telephone
Internet
Copyright
Occupational Pensions Customer Helpline
Personal Pensions Customer Helpline
Application Forms
Survey Results
Customer Survey Questionnaire

Update 66 - 30 June 2000

Flexibility in Pension Provision
Builds on PSO Update No 54 (The Improved Flexibility in Pension Provision) which outlined modifications to discretionary practice allowing greater flexibility in the operation of occupational pension schemes and buy-out contracts.

Update 66 clarifies and modifies arrangements for both annuity purchase deferral combined with income drawdown for money purchase occupational pension schemes, and the flexible use of Additional Voluntary Contributions (AVCs).

Update 67 - 30 June 2000

Customer Service Acknowledgements
PSO will no longer issue acknowledgements for listed items.

Update 68 - 29 August 2000

Occupational Pension Schemes - Equal Treatment
PSO Update Number 27, issued in May 1997, announced changes to discretionary practice to enable equal treatment requirements to be met by approved occupational pension schemes. This followed decisions by the European Court of Justice, which were brought into UK Statute law with effect from 1 January 1996 by sections 62-66 of the Pensions Act 1995 and related Regulations.

Update 68 aimed to clarify the scope of the easements in Update 27.

Update 69 - 29 August 2000

Enhancing the Role of the Pensioneer Trustee
This gave all Pensioneer Trustees:
    • 90 Days to complete and return a new undertaking and supply a list of SSASs where they act as PT.
    • 6 Months to become co-signatories of scheme bank accounts.
    • 12 Months to become co-owners of assets.

Update 70 - 29 August 2000

Small Self Administered Schemes (SSASs) used to wind-up when the employer went into liquidation without a successor. This Update announced more flexible options, subject to SSASs having suitable rule alterations and meeting the co-signatory and co-ownership requirements of PSO Update No 69.

Update 71 - 29 August 2000

Doing More Business by Telephone
The PSO transacts a certain amount of business by telephone. This serves the interests of cost efficiency and faster response times.

This Update sets out the circumstances in which PSO will seek to use the telephone and asks for customers' co-operation to facilitate increased business by telephone.

Pension Sharing on Divorce or Nullity

April 2000 saw some of the final pieces of the legislative framework put into place to pave the way for pensions to be shared as part of the financial settlement to a divorce or annulment of marriage. The new sharing provisions will come into effect on 1 December 2000.

As part of this process occupational pension schemes wanting tax approval on or after 10 May 2000 must have pension sharing on divorce provisions in their governing documentation before they can be approved.

Applications for tax approval will not be rejected if the scheme documentation does not contain the required provisions. Instead they will be given interim authorisation by the Pension Schemes Office (PSO) if everything else in respect of the application is in order. Interim authorisation will allow for tax relief to be given, on a provisional basis, for contributions paid into the scheme. However, formal approval will not be given until adoption of the necessary pension sharing on divorce provisions.

Existing Approval Requirements

The new pension sharing on divorce provisions could not be accommodated within the existing legislation. In particular there were limits on and conditions attached to the benefits that could be paid out of tax approved occupational pension schemes.

For example, benefits could only be paid to the employees or former employees of the company who had set up the scheme or to the beneficiaries of those employees and former employees; a beneficiary being a widow, widower or dependant, such as a child, of the employee or former employee. Also, the benefits would usually be limited in amount and the recipient could not assign those benefits to some other person.

Pension benefits could be taken into account as part of a divorce settlement. The courts could take the value of the benefits into account and offset that value against the value of other assets that were included in the settlement. The courts could place an attachment or earmarking order to the benefits when they came into payment. These arrangements may continue to apply.

Also, courts were latterly able to look to the 1995 House of Lords ruling in the case of Brooks v Brooks to effect a pension sharing order. However, the Brooks case could not be used as an authority to share pensions on divorce in all cases and, if it was used, care needed to be taken to ensure that the approval of the scheme was not prejudiced so as to protect the interests of other scheme members. This meant that each request to share a pension on the principles of the Brooks case needed ad hoc consideration by the PSO.

The New Provisions

It will now be possible for the courts to order schemes to provide benefits, that would have been paid to an employee or former employee, to the ex-spouse of an employee or former employee instead. In Scotland it can be done by an agreement. This can be achieved by the scheme offering membership to the ex-spouse or by transferring out the benefits that have been allotted to the ex-spouse to some other tax approved pension arrangement.

The new powers and provisions were introduced in the Welfare Reform and Pensions Act 1999 and they apply from 1 December 2000. There has also been a complementary change to the tax approval legislation and practice.

As schemes might be required to pay benefits to a member's ex-spouse, new limitations and conditions have been added to the existing conditions for obtaining tax approval. New limitations apply to scheme members who have relinquished their benefits and there are new limitations and conditions for the payment of benefits to the member's ex-spouse.

The benefits that can be paid to the ex-spouse broadly follow the benefits that would have been available to the scheme member. A pension can be paid to the ex-spouse, which might include an option to exchange some of it for a tax-free lump sum.

Death benefits can also be paid to the widow(er) or dependants of the ex-spouse. Death benefits might include a tax-free lump sum.

Pensions paid to the ex-spouse or the widow(er) or dependants of the ex-spouse are assessable in the hands of the recipient under Schedule E.

Existing Approved Schemes

Schemes that were tax approved before 10 May 2000 and do not have the pension sharing on divorce provisions in their documentation will not lose tax approval as a result. After 1 December 2000, it will be expected that these schemes incorporate the required provisions at a next convenient opportunity - when other than a trivial amendment is made to the scheme documentation. New schemes wanting tax approval must have the new tax approval limitations relating to pension sharing on divorce. These limitations will be applied to existing approved schemes by an overriding statute instead. The overriding legislation is in Schedule 10, Finance Act 1999.

New Regulations

There have been consequential amendments to the Retirement Benefits Schemes (Restriction on Discretion to Approve) (Small Self-administered Schemes) Regulations 1991 [SI 1991 No 1614 - now also amended by SI 2000 No 1086] and the Retirement Benefits Schemes (Restriction on Discretion to Approve)(Additional Voluntary Contributions) Regulations 1993 [SI 1993 No 3016 - now amended by SI 2000 No 1088] and the overriding legislation has been modified by the Retirement Benefits Schemes (Sharing of Pensions on Divorce or Annulment) Regulations 2000 [SI 2000 No 1085].

Personal Pensions

The rules of personal pension schemes seeking tax approval on or after 10 May 2000 must also include pension sharing on divorce provisions and like occupational pension schemes, the rules of existing tax approved schemes have to be amended in due course to allow for pension sharing.

A pension sharing order is implemented by the personal pension scheme as follows. Members of personal pension schemes have their own "arrangements" within the scheme. The part of the member's fund awarded to the ex-spouse in the divorce settlement would not stay in the member's arrangement; instead it would be placed in a new arrangement for the ex-spouse. Alternatively the amount allocated to the ex-spouse, could be transferred to another tax approved pension scheme or arrangement.

The range of benefits that can be paid by a personal pension scheme to the ex-spouse of a member include an annuity, income withdrawal from the fund allocated to the ex-spouse and a tax-free lump sum of 25% of the ex-spouse's fund.

Death benefits can also be paid to the widow(er) or dependants of the ex-spouse, which might include a tax-free lump sum if the ex-spouse was not in receipt of any benefits at the time of death or a lump sum taxed at 35%.

Annuity and income withdrawals paid to the ex-spouse or widow(er) or dependant of an ex-spouse are assessable in the hands of the recipient under Schedule E.

Publicity

The PSO have issued Update No 62 that sets out the new tax approval requirements relating to pension sharing on divorce. Publicity was also given in an IR Press Release dated 19 April 2000. The Update, Press Release and Regulations can be found on the IR website, www.inlandrevenue.gov.uk

Contact Point

Trevor Smeath
Pension Schemes Office
Yorke House
PO Box 62
Castle Meadow Road
Nottingham
NG2 1BG

Tel: 0115 974 1607

Payroll Giving - now an even better way to give

A campaign to promote the Payroll Giving Scheme was launched on 3 October by Melanie Johnson the Economic Secretary. The campaign will run for the rest of this year and through the next 2 years.

The campaign is being managed by a Communications Agency - Cramm Francis Wolf. It will begin with a direct mailshot to employers with more than 100 employees, inviting them to get in touch with a call centre or the new web page on the IR website for an Employer's Pack. The pack will tell employers how to set up a scheme, or to relaunch an existing one. This will be accompanied by advertisements in both the national and specialist press.

Payroll Giving is a tax effective way for employees to give regularly to their favourite charities whether these are large national charities or small local ones. Under the scheme, employees make donations from their pre-tax pay and so get tax relief straight away at their top rate of tax.

A number of improvements were made to the Payroll Giving Scheme in the Budget this year as part of the "Getting Britain Giving" package of charity tax reliefs.

From April 2000, there is no limit to the amount which employees can give through the scheme. And until April 2003, the Government will add ten per cent to all Payroll Giving donations.

The Payroll Giving scheme is simple and inexpensive for employers to run. Inland Revenue approved agencies carry out most of the administration of the scheme on behalf of employers. It can help employers and their staff build up a good relationship with each other and with the community in which they work.

Further Information

Employers can get an Information Pack about Payroll Giving by calling the campaign helpline on 0845 604 9000. Help is also available from the Payroll Giving pages on the Inland Revenue website at www.inlandrevenue.gov.uk/payrollgiving.

Contacts

For more information on Payroll Giving telephone Inland Revenue (Charities) on 0151 472 6029/6053.

! This Article Is No Longer Current (Deleted Index 2001)

Millions up for grabs from the Inland Revenue!

The Chancellor announced another Taxbackcampaign in the Budget Day press notice "Getting it right". The campaign is intended:

  • to remind/tell savers who are eligible to claim back tax deducted from their bank and building society interest how to do so. This will include non-taxpayers and taxpayers in the 10p rateband; and
  • to remind/tell savers who are non-taxpayers and therefore eligible to register to receive interest without tax deducted how to do so.

Why a Taxbackcampaign?

We want taxpayers to pay the right amount of tax. That means no one should pay tax if their personal tax allowances cover their total taxable income.

Savers with money in a bank or building society who aren't due to pay tax can register their accounts to receive their interest without tax being taken off. They only have to complete a simple form to tell their bank or building society they are not due to pay any tax. Savers who don't register their accounts can claim back any overpaid tax deducted from their interest.

Why doesn't the Inland Revenue just give savers who have had too much tax deducted from their interest their money back?

We don't know who is eligible to claim back tax unless people tell us. But we know there are several million savers who may be entitled to some tax back on their savings interest. That is why we are having a Taxbackcampaign.

What is happening during the Taxbackcampaign?

A new Taxbackwebpage was set up on the IR web-site on Budget Day; and a new Taxbackleaflet P/TXB/1 "Are you paying too much tax on your savings?" was published this month. This tells low income savers who want help in claiming tax back where to go for more information, and publicises the special Taxbacktelephone Helpline (0845 077 6543). It also includes the Registration Helpline (0845 980 0645).

At the end of this month widespread media coverage will be achieved through a high profile Taxbacktheme week. Regional and local initiatives will raise awareness throughout the country. Local offices have plans for visiting homes for elderly people and shopping centres. Events include the use of a vintage double-decker bus, a group of cheerleaders, and a display called "Taxman and Robbin". Articles will be supplied to regional and local press, and there will be some limited paid advertising in selected newspapers.

Representative organisations such as The Low Incomes Tax Reform Group, Age Concern, and Help the Aged have been consulted about the campaign, as well as the British Bankers' Association and The Building Societies Association.

Inland Revenue Extra-Statutory Concessions and Statements of Practice issued between 1 August 2000 and 30 September 2000

Extra Statutory Concessions

 

Number

Title

Date of Issue

F19

Decorations awarded for valour or gallant conduct exempt from IHT

21/08/00

Statement of Practice

Number Title Date of Issue

SP1/00

Corporate Venturing Scheme; applications for advance clearance under Part X, Schedule 15, FA 2000

03/08/00

SP2/00

Venture Capital Trusts, the Enterprise Investment Scheme, the Corporate Venturing Scheme and Enterprise Management Incentives

03/08/00

SP3/00

Enterprise Investment Scheme, Venture Capital Trusts, Corporate Venturing Scheme, Enterprise Management Incentives and Capital Gains Tax Reinvestment Relief

03/08/00

SP4/00

Tonnage Tax

25/08/00

You can get copies of SPs and ESCs from the Inland Revenue Visitors Information Centre, Ground Floor, South West Wing, Bush House, Strand, London WC2B 4RD or by ringing the Inland Revenue Enquiry line on 020 7438 6420.

Content

The content of Tax Bulletin gives the views of our technical specialists on particular issues. The information published is reported because it may be of interest to tax practitioners. Publication will be six times a year, and include a cumulative index issued on an annual basis.

  • You can expect that interpretations of the law contained in the Bulletin will normally be applied in relevant cases, but this is subject to a number of qualifications.
  • Particular cases may turn on their own facts, or context, and because every possible situation cannot be covered, there may be circumstances in which the interpretation given here will not apply.
  • There may also be circumstances in which the Board would find it necessary to argue for a different interpretation in appeal proceedings.
  • The Bulletin does not replace formal Statements of Practice.
  • The Board's view of the law may change in the future. Readers will be notified of any changes in future editions.

Nothing in this Bulletin affects a taxpayer's right of appeal on any point.

Letters on any article appearing in Tax Bulletin should be sent to the Editor, Sarah Guerra, Room 402, 22 Kingsway, London WC2B 6NR. We are sorry though that neither she nor our contributors will normally be able to enter into correspondence about Tax Bulletin or its contents.

Subscription

The subscription for 2000 is £22. If you would like to subscribe to Tax Bulletin please send your name and address together with your cheque to Inland Revenue, Finance Division, Barrington Road, Worthing, West Sussex BN12 4XH. Cheques should be crossed and made payable to "Inland Revenue".

If you would like information regarding Tax Bulletin subscription or distribution please contact Miss F. Chowdhury, Room 439, 22 Kingsway, London WC2B 6NR. Telephone: 020 7438 7812. For more general information regarding Tax Bulletin, please contact Ms Nahid Shariff, Assistant Editor, on 020 7438 7842 or at the address below.

Copyright

Tax Bulletin is covered by Crown Copyright. There is no objection to firms copying the Bulletin for their own use. Anyone wishing to republish Tax Bulletin or extracts more widely should write for permission to Ms Nahid Shariff, Assistant Editor, Room 408, 22 Kingsway, London, WC2B 6NR.

 

 

tax analysts logo

   
 
 Top