Owner-Managed Businesses

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Owner-Managed Businesses Guidance

Direct taxes CIOT letter to HMRC regarding non-domiciled individuals, double remittances and 6 April 2025

The CIOT has written to HMRC concerning the Finance Act 2025 and double remittances into the UK after 6 April 2025, providing technical analysis on the construction of s 809P(12) as in force until 5 April 2025.

The letter states that the CIOT continues to disagree with HMRC's interpretation of s 809P(12) prior to 5 April and includes a note with further technical analysis for consideration. The CIOT questions HMRC's claim of longstanding interpretation, citing the wording of the explanatory note to clause 40 and schedule 9 of the Finance Bill.

Assuming HMRC's interpretation is correct, the CIOT requests clarification on why certain groups do not qualify for relief in schedule 9, para 6.

See Simon's Taxes E6.324DA.

Updated guidance on MTD for income tax

HMRC has updated its guidance. Continue reading the full document

Class 4 national insurance contributions

Class 4 NICs are paid by self-employed individuals and partners on profits arising within the UK. This guidance note discusses Class 4 contributions. For information on Class 2, see

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Trusts and Inheritance Tax

Tax on UK resident beneficiaries of non-resident trusts - overview

UK resident beneficiaries of non-resident trusts are subject to UK tax on payments or benefits received from the trust. They are liable for income tax on distributions and may also be liable for

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Gilts

'Gilts' are securities also known as gilt-edged securities, government securities, or treasury stock. The government sells gilts to fund the deficit between public spending and tax receipts. Typically, interest is paid to the holder of the gilt.

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