
This is an HMRC consultation where your knowledge or tax partner should consider sending a response
It never rains but it pours.
Thank you to the Daily Telegraph for bringing the fact that HMRC closing an inheritance tax loophole to my attention.
HMRC is consulting until 4th June (so not long!) on extending Uncertain Tax Treatment rules (UTT) to wealthy individuals and trusts and to extend it to cover IHT, CGT, NICs, Stamp Duty Land Tax and more. If you know people with an income over £200,000 or assets over £2m, this is a consultation you cannot avoid knowing about and having a view on.
Opportunities to Extend Uncertain Tax Treatment – GOV.UK
Essentially the extension of UTT rules would cover all sorts of situations around share and asset ownership and transfer. It may even capture arrangements that have historically been seen as fairly straightforward from a tax perspective, e.g. tax advantaged investment and share schemes, because of the knotty issue of valuation.
The current plan is broadly to keep the threshold at £5m, but if this extension to UTT is implemented, it does beg the question whether in due course the threshold could be lowered.
We will be thinking about our own response – if you would like me to ask HMRC if we could bring a delegation to meet with the officials conducting the consultation, let me know and I will get in touch with them.
In the meantime, we remain open for business around valuations of companies, shares and other assets.