Transcript Document
Outlook for the UK Economy Winter Update 5 December 2014 Speaker: Professor Joe Nellis Pro-Vice-Chancellor & Director School of Management Cranfield University State of the Nation Upward revisions to GDP in recent months - resulting in a £1.7bn bill demanded by EU (reduced?) UK GDP is now well above the pre-crisis peak in Q1 2008 - and is set to grow by around 3% this year Growth is looking fairly well balanced - with investment growth accounting for a significant share Pace of growth will ease in 2015 - easing of business and consumer confidence - domestic political uncertainty - international factors, e.g. Japan and Eurozone! GDP Quarterly Growth Rate Source: www.tradingeconomics.com | UK Office for National Statistics GDP Annual Growth Rate Source: www.tradingeconomics.com | UK Office for National Statistics CBI Business Confidence Index Government Finances The solid economic recovery has NOT yet boosted government tax revenues - net government borrowing is UP 6% on last year - and was forecast to be 10% LOWER Income tax receipts are disappointing due to: - shift to lower paid work for many - rises in the tax-free personal allowance - some one-off factors Likely to be even tighter fiscal squeeze in the coming years regardless of Election outcome - if deficit reduction plans are to be met Austerity continues Government Finances By 2018/19, day-to-day government spending as a share of GDP is forecast to fall to its lowest level since official records began in 1948! If Health, Education and Overseas Development Aid spending remain protected, then major cuts are inevitable across other departments Budget Deficit (as % of GDP) Source: www.tradingeconomics.com | Eurostat National Debt (as % of GDP) Source: www.tradingeconomics.com | UK Office for National Statistics 10 year Government Bond Yields Source: www.tradingeconomics.com | United Kingdom Department of Treasury Monetary Policy Base rate still on hold at 0.5% - for 5 years! But a rise is expected in 2015 (?) - as wages start to rise (slowly…) - alongside a 3% rise in minimum wage rate - and as firms begin to report recruitment difficulties A global liquidity glut is keeping long-term rates very low - 10 year bond yields are just over 2% - but should start to rise gradually year-by-year So..... no big surprises ahead! Prices & Wages Core inflation grew by 1.3% in October - below Bank of England 2% target for almost a year Key factors: - falling key food prices lower oil pushing down petrol prices weak underlying demand pressures sterling strength against the euro Low stable inflation looks set to continue - and may fall below 1% soon A letter from Mark Carney…….? Prices & Wages Wages will continue to recover slowly in 2015 - and will be partly offset by productivity - as corporate investment continues to grow Sustainable long term economic growth coupled with low inflation.... Boring but good! Inflation Rate Consumer Demand Key component of GDP - but has been punching below its weight in recent quarters as debt reduction continues - likely to continue to do so as wages rise slowly But “real” pay increases will start to come through in 2015 to support stronger spending & confidence Employment levels continuing to rise - and unemployment continuing to fall Unemployment Rate Source: www.tradingeconomics.com | UK Office for National Statistics The Housing Market Signs are that the market is beginning to cool - Reactions to various policy interventions o Mortgage Market Review o Tougher affordability checks House price inflation moderating - but not everywhere! Positive factors: - strong population growth - improvement in household incomes - easing of credit availability The Housing Market Negative factors: - expected rise in interest rates - squeeze on affordability (especially London and southern regions) - restriction on size of mortgage loans to maximum of 4.5 times income to no more than 15% of new mortgage lending by any bank - checks on borrowers’ ability to pay at interest rate 3% above current level Average UK House Price Source: Nationwide UK House Price Movements (Q on Q) Source: Nationwide UK House Price Movements (Y on Y) Source: Nationwide Affordability of Housing Source: Nationwide, ONS Where Are We Going? Forecasts for the Economy + (% changes on previous year) Forecasts 2012 2013 2014 2015 2016 2017 2018 GDP Consumer Spending 0.7 1.1 1.7 1.6 3.1 2.1 2.4 2.3 2.3 2.2 2.5 2.0 2.5 1.8 Fixed Investment Net Govt. Borrowing* 0.7 7.2 3.2 5.6 9.2 4.9 6.5 3.9 7.7 2.4 7.9 1.0 6.2 0.1 Average Earnings 2.4 1.4 1.1 2.1 2.8 3.3 3.8 Inflation (CPI) Bank Rate 2.8 0.5 2.6 0.5 1.6 0.5 1.3 1.1 1.7 2.1 2.1 3.1 2.2 3.8 + Source: ITEM Club October 2014 * Fiscal years, as % of GDP Outlook Slowdown in economy growth in 2015 due to political uncertainty at home and abroad Low inflation looks set to stay! falling commodity prices Interest rates will increase only slowly A Goldilocks Economy…. - not too hot… not too cold… just about right! Q&A Winter Update, Autumn Statement and planning for 2015 for SMEs Presented by:Bob Trunchion, Tom Byng and Ricky Noimark December 2014 © MHA MacIntyre Hudson 2014 Running Order… • Introduction • Topical tax issues regarding SMEs – How is Corporation tax moving: • Patent Box Taxes and R&D • Capital Allowances – – – – ATED Cash extraction and Pensions Freedom Some topical VAT & Duty Points for SME The Autumn Statement • Some Pre Election Points •Q&A © MHA MacIntyre Hudson 2014 Draft Finance Bill Process & the Autumn Statement • Historically, we had Autumn Spending announcements and Spring Budget Statements • Then moved to an autumn Budget under Mr Clarke • Then Pre Budget Reports under Mr Brown with a Spring Budget • Return to the Autumn Statement under Mr Osborne with draft Finance Bill clauses (Legislation Day) • Why – Complexity of Legislation…….. and consultation(?) • So tax and spending announcements at this time to include anti-avoidance, some new measures and some of next year’s income tax and NIC rates/allowance details • This year’s timetable ? – 3 December 2014 - Autumn Statement – Draft Finance Bill 2014 – 10 December 2014 (Legislation Day) – March 2015 Budget but the election on 7 May……. © MHA MacIntyre Hudson 2014 Legislative Process • Proposals from Budget and FA 2013 and 2014 that come into effect from April 2015 • Proposals from this Autumn Statement coming into effect April 2015 • Proposals from Budget and FA 2014 and 2015 effective immediately • Proposals from Budgets that never become effective • Process creates some sense of déjà vu © MHA MacIntyre Hudson 2014 Autumn Statement 2014 Government spending 2014/15 © MHA MacIntyre Hudson 2014 Autumn Statement 2014 Government receipts 2014/15 © MHA MacIntyre Hudson 2014 Autumn Statement 2014 Tax yields – from 2014/15 Receipts 2014/15 2015/16 2016/17 2017/18 2018/19 % shift Income tax 166.5 176.8 189.2 201.3 213.2 28.04% NIC 110.9 115.0 126.1 132.0 138.2 25.63% VAT 110.7 115.0 119.2 123.3 127.7 15.35% CT 41.4 42.3 42.6 44.5 45.9 10.86% CGT 5.4 6.7 7.5 8.2 9.0 66.66% IHT 3.9 4.3 4.9 5.4 5.8 48.71% © MHA MacIntyre Hudson 2014 • Falling CT Rates FY2011 FY2012 FY2013 FY2014 FY2015 • 26% • 24% • 23% • 21% • 20% Marginal rate between £300k and £1.5 million: FY2011 FY2012 FY2013 • 27.5% • 25% • 23.75% MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA FY2014 • 21.25% FY2015 • 20% • Associated Companies are no longer relevant with single 20% CT rate from 2015? • Currently divide Upper and Lower limits by number of associated companies (FY2014) • New 51% subsidiary definition in FA 2014 – 1/4/2015 • Upper £1,500,000 limit (and Associated Company splitting thereof still relevant for Quarterly Instalment Payments (QIP) • Serious cash flow impact first year that applies MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA Quarterly Instalment Payments • Payments due , EG y/e 31 December 2014: • 25% 6m and 13 days after start of AP 14 July 2014 • 50% 3m after 1st instalment 14 Oct 2014 • 75% 14 days after end of AP 14 Jan 2015 • Balance - 3m and 14 days after AP 14 April 2015 • Instead of 100% due 9 months after end of AP - 1 October 2015 - Significant impact on cash flow • Still worth minimising number of Associated companies to stay out of QIPS (dormant subs OK) © MHA MacIntyre Hudson 2014 Patent box 10% tax rates Granted patent Registered in (or pending)? the UK or EPO Outright ownership June 2016 Closed to new entrants OR Exclusive License (by reference to territory) June 2021 Active Development Ownership Condition MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA Abolished Patent box Patent box 2.0 R&D must have taken place in the UK Will impact • Non UK group companies doing R&D • Foreign HQ groups licensing to UK Tracking and tracing? Do you benefit from any patents where the R&D was performed overseas? Elect into Patent Box 1.0 before June 2016 MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA 5 years guaranteed R&D tax relief More free cash! Seek to achieve a scientific or technological advance AND Resolution of scientific or technological uncertainty Two regimes: SME Large Benefit Benefit i.e. 26% cash tax saving (up from 225% / 25%) • 33.35% (was 32.6% and 24.75%) cash back if loss making profitable • 8.8% (was 8%) cash back if not tax paying • 230% tax deduction if profitable, • Above the line • 8.8% (was 8%) tax saving if • 500 employees, AND • €100m turnover, OR • €86m balance sheet MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA R&D tax relief SME scheme examples Profitable, with no R&D relief Profitable, claiming R&D relief Loss making, with no R&D relief Loss making, claiming R&D relief 5,000 5,000 800 800 R&D expenses (1,000) (1,000) (1,000) (1,000) Other expenses (1,000) (1,000) (1,000) (1,000) 3,000 3,000 (1,200) (1,200) Turnover Profit / (loss) Tax relief (1,300) (1,300) Loss surrender Taxable profit Tax payable Losses to carry forward MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA 2,300 3,000 1,700 600 340 (334) 1,200 200 R&D tax relief Large scheme examples Turnover R&D expenses Profitable, with no R&D relief Profitable, claiming R&D relief Loss making, with no R&D relief Loss making, claiming R&D relief 5,000 5,000 800 800 (1,000) (1,000) (1,000) (1,000) ATL credit Other expenses Profit / (loss) Tax charge 110 (1,000) (1,000) (1,000) (1,000) 3,000 3,110 (1,200) (1,090) 600 622 ATL credit Tax payable Losses to carry forward MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA 110 600 (110) (88) 512 (88) 1,200 100 +22 tax credit R&D tax relief Examples As well as ‘obvious’ R&D… • Software • Software developers • New operating systems in ANY industry • e.g. travel agent, window manufacturer • Video games development • Manufacturing • Machine development / process improvements • Product development • Property and construction • Architects • Building design services • Food • Improved taste, texture • Reduced sugar, salt, fat MHAMacIntyre MacIntyreHudson Hudson2014 2014 ©©MHA Capital allowances and AIA • On first – £50,000 to March 2010 – £100,000 to March 2012 – £25,000 to December 2012 – £250,000 to March 2014 – £500,000 to December 2015 – £25,000 onwards?? • Free to allocate AIA between companies and types of expenditure – 8% v 18% – Tax rates – Date of expenditure © MHA MacIntyre Hudson 2014 AIA • Date of expenditure crucial • Easy for the next year • However… • Example – New machine purchase for £500,000 – Buy pre 31 December 2015, potential max AIA of £500,000 (if 31 December 2015 year end) – Buy post, max AIA = £25,000 (could be less) • Need to seek advice in advance! © MHA MacIntyre Hudson 2014 AIA Example 1 Example 1 – Year ended 31 March 2016 – Maximum allowance: £381,250 (being 9/12 x £500,000 = £375,000 plus 3/12 x £25,000 = £6,250). – New machine £350,000 – Buy pre 31 December 2015, max AIA = £381,250 – Buy post, max AIA = £6,250 © MHA MacIntyre Hudson 2014 Example 2 More realistic example – Year ended 30 June 2014 – Maximum allowance: £312,500 (being 9/12 x £250,000 = £187,500 plus 3/12 x £500,000 = £125,000). – New machine purchased on 30 April 2014 for £500,000 – AIA = £312,500 – Shorten AP to 31 March 2014 – Expenditure in 31 March 2015 AP, where AIA = £500,000 © MHA MacIntyre Hudson 2014 Fixtures in Building Typical proportions: • Air conditioned office 20% - 40% • Hotel 20% - 35% • Modern office 10% - 25% • Industrial unit 5% - 20% • Shop shell 2% - 8% © MHA MacIntyre Hudson 2014 Fixtures Post April 2014 Key issues • Sellers – Ensure CA history in order • Purchasers – Ensure solicitor agrees CA value within sale and purchase contract • Most importantly, get advice early! © MHA MacIntyre Hudson 2014 ATED Includes Limited Companies, LLP with corporate partner and Collective Investment Scheme Exemptions only for charitable bodies, otherwise need to file a return even if you qualify for a relief (e.g. property developer, buy to let…) Reporting date is annually on 30 April unless…. …mid year acquisitions need to be reported within 30 days © MHA MacIntyre Hudson 2014 ATED – what to look for…… April 2015 and then April 2016 • Annual charge – Companies etc. •Property ≥ £500,000 from 2016 •Current rates (subject to index linking) £0.5m - £1m £3,500 £1m - £2m £7,000 £2m - £5m £23,350* £5m - £10m £54,450* £10m - £20m £109,050* £20m + £218,200* * New rates announced in Autumn Statement 2014 © MHA MacIntyre Hudson 2014 More on ATED Failure to register – normal HMRC penalty regime …. £100 late filing 3 months - £10 a day for 90 days 6 months – Greater of 5% or £300 12 months – Greater of 5% or £300 More than 5% of tax if deliberate Consultation underway on simplifying reporting requirements Plan in advance for April 2015 changes If you do not file a return, any CGT gains from ATED properties will be taxed at 28%! © MHA MacIntyre Hudson 2014 Extraction of company profits Methods generally used to extract profits: • Dividends • Salaries and bonuses • Benefits in kind • Pension contributions • Loans from the company • Interest on loans to the company • Rent from personally owned assets © MHA MacIntyre Hudson 2014 Pensions Freedom © MHA MacIntyre Hudson 2014 Pensions Freedom Overview: • Permissive statutory override of scheme rules to allow new flexibility • Free to transfer between defined contribution schemes • But scheme rules may prohibit – watch! • Tax rules relaxed to allow more innovative products • Anti-avoidance to prevent pension recycling - £10,000 cap on contributions if in some types of drawdown • Increase minimum age to access pension to 57 – 2028 • Reduce 55% charge on death to zero (<75) – or MR IT (>75) © MHA MacIntyre Hudson 2014 Pensions Freedom another point:• Treasury expects to net additional £1bn tax receipts from earlier drawdown over next two years. • £1bn or more per year thereafter • This means a grey injection of about £2.5 billion of extra spending into the economy…….. © MHA MacIntyre Hudson 2014 Pensions Freedom • Are the changes positive? – far greater flexibility – many more options for people – remove complexity! (?) – The Government is treating us like adults! Will people blow their pension fund and rely on the State? – But what about Australia? – Individuals will have right to free and impartial advice (note – now guidance) – Where will proper advice come from? © MHA MacIntyre Hudson 2014 Death and Social Care • Govt. changing the tax charge on funds in drawdown product at death or uncrystallised after age 75 • Accepted that current rate of 55% is too high • For Social Care - these products will be treated similarly to current drawdown products - any capital held in drawdown product excluded from capital means tests • Those who choose to draw down full pension pot quickly and manage it directly will need to consider how this could affect their entitlement to welfare and social care support © MHA MacIntyre Hudson 2014 Passing your pension on… • HM Treasury release 29 September 2014 – legislation and Autumn Statement confirm going ahead! • 55% tax rate on death goes from 6 April 2015 • For pension funds (not DB) untouched or in flexi access • Death prior to 75 – passes tax free to beneficiary • Death over 75 - passes to beneficiary – extraction thereafter at their MR (eventually – after consultation) but fixed 45% initially from 6 April 2015 • Think of the planning opportunities! • Watch £1.25 Million life time limit always © MHA MacIntyre Hudson 2014 Passing your pension on… • Autumn Statement – Unlikely for a new administration to be able to put the genie back in the bottle! • Not all DC schemes will allow flexibility • Watch State and other DB schemes • Then get it in place after 6 April 2015? © MHA MacIntyre Hudson 2014 MOSS – Mini One Stop Shop • From 1 January 2015, supplies of telecommunications, broadcasting and electronically supplied services made by EU suppliers to private individuals and non-business customers will be taxable in the Member State of the customer. • Digital Services may include the following: Broadcasting – TV/Satellite or radio programs Telecommunication services - includes fixed and mobile calls and connection to the internet Electronic-services – sales of apps, music downloads, e-books, on-line auctions, gaming, video on demand, provision of information, sale of advertising space and other downloaded applications © MHA MacIntyre Hudson 2014 Why change • To ensure the services are being taxed where consumed • Why has HMRC introduced MOSS? - As a way of helping taxpayers - Without it B2C suppliers may need to register in many countries - A single on-line return will reduce costs and simplify the burden © MHA MacIntyre Hudson 2014 Why change • Registration now available • Quarterly returns due by the 20th of the following month • 1 separate page per member state country • 1 single payment made • HMRC distributes to other authorities • Only output tax is accounted for on the MOSS return • Keep records for 10 years • Optional scheme can deregister but can’t use again for 6 months © MHA MacIntyre Hudson 2014 E-service VAT Examples Bob runs an internet dating agency Jaqui is an Irish resident and pays £100 a month Issues December 2014 sub is £100 inc UK VAT at 20% Bob pays 16.67 on his UK VAT return January 2015 sub is £100 inc VAT at 23% Bob pays 18.70 via MOSS © MHA MacIntyre Hudson 2014 E-service VAT Example 2 Brendan is a musician and sells music for Ringtone Apps via a license agreement to a German company The German Company sells downloads to final consumers Issues Brendan is in a B2B transaction and is not affected by the changes But what if Brendan remained contractually liable……. © MHA MacIntyre Hudson 2014 Customs Codes - Some Surprises • Two (potentially) significant changes included • Change to the concept of a retail sale in a customs warehouse • Proposed Implementing Act abolishes the earlier sale concept © MHA MacIntyre Hudson 2014 The Earlier Sale Concept US manufacturer sells to Sales co UK customer Goods Settlement $50,000 Invoice $20,000 Invoice $50,000 US sales co sells to Swiss sales co Invoice $30,000 Swiss sales co sells to customer For Customs Duty value can be 1st sale now looking to abolish - needs to be © MHA MacIntyre Hudson 2014 Issues that can affect you if you import • Is this necessary? • Who is responsible? • We don’t pay any duty • Do we import anything? • Its not my job! • Just get it here! • Just get it there! • We’ve always done it this way! • Our agent handles everything! • We called Customs – its ok! © MHA MacIntyre Hudson 2014 FATCA Myths with thanks to STEP, ICAEW & Law Society • MYTH 1 • It doesn’t apply to me, I’m British • MYTH 2 • It doesn’t apply to me because there are no US connections (indicia), assets or income • MYTH 3 • It doesn’t apply to me because it is worth less than $50,000/$250,000/$1,000,000 • Me = An entity – company, LLP, Trust, partnership…… © MHA MacIntyre Hudson 2014 FATCA FACTS • The non US world is split into entities and non entities! (?) • If you are an entity, you are either a Financial Institution (“FI”) or a Non Financial Foreign Entity (“NFFE”) • If you are an FI (often a trust), you will need to register with the IRS and get a“GIIN” and report (usually) to HMRC but be able to give your GIIN to banks and investment advisors – before they can do business with you. • NFFEs need to understand their FATCA status and be able to prove it to banks etc before they can do business with you. – NFFEs can be active (or trading) – no problems – NFFEs can be passive – need to tell bank etc of US connections © MHA MacIntyre Hudson 2014 Autumn Statement 2014 Pre-election tax landscape… 07.05.15… One Budget to go! Some manifesto promises to date: • £50K higher rate threshold • Personal allowance pledges • The “Mansion Tax” issues • CGT proposals • 50% v 45% Income Tax • Anti-avoidance/tackling tax fraud © MHA MacIntyre Hudson 2014 BEPS & Tax Avoidance in the News Starbucks to move European HQ to UK 16 April 2014 Starbucks said the UK was its fastest growing and largest market in Europe Starbucks is to move its European head office from Amsterdam to London by the end of the year, following a row over corporate tax avoidance. "This move will mean we pay more tax in the UK," the company said © MHA MacIntyre Hudson 2014 70 71 © MHA MacIntyre Hudson 2014 72 © MHA MacIntyre Hudson 2014 And Some Figures…… From HMRC • Tax Gap - £34Bn which is 6.8% of total! – – – – – – £3.1Bn £4.1Bn £5.9Bn £5.4Bn £7.1Bn £8.4Bn – – – – – – Avoidance Evasion Black Economy Criminality Errors, Mistakes, Failure to collect tax The rest….. • Where does avoidance fall in the list? © MHA MacIntyre Hudson 2014 74 © MHA MacIntyre Hudson 2014 75 © MHA MacIntyre Hudson 2014 We don't pay taxes. Only the little people pay taxes Leona Helmsley American property tycoon, New York Times (12 July 1989); Newsweek (24 July 1989) p11 Helmsley later served 19 months in prison for tax evasion. 76 © MHA MacIntyre Hudson 2014 Some Other Autumn Statement Points • ISAs to retain status on transfers caused by death (interspouse = no IHT either, watch IHT otherwise) • Business rates – relief for SMEs • Incorporation restrictions • Employment Allowance extended to carers • Non Domiciled persons to pay more tax • APD reduced for children • SDLT on residential property © MHA MacIntyre Hudson 2014 SDLT on residential property • From 4 December 2015: • Slabs gone – bands in…. • 0 - £125,000 • £125,001 - £250,000 • £251,000 - £925,000 • £925,001 - £1,500,000 • £1,500,000+ © MHA MacIntyre Hudson 2014 Nil 2% 5% 10% 12% Consequences Type of Home Av Help to Buy Av Family Home Average London Larger Home © MHA MacIntyre Hudson 2014 Value £ 125,000 SDLT £ Old 1,850 New 1,200 275,000 Old 8,250 New 3,750 510,000 Old 20,400 New 15,500 2,100,000 Old 147,000 New 165,750 Change £ -650 -4,500 -4,900 +18,750 Some Pre Election Planning? • Entrepreneur’s Relief from CGT – Today, the first £10M of an entrepreneurial gain is taxed at 10% rather than 28% – PAC say £2B more relief given than expected – Will there be restrictions in future? – Should we crystallise today if we are going to sell anyway? • IHT Planning – What will happen to BPR? – Trust Tax likely to change – Should we do it today? • Income Tax Planning – Should we take income today if 50% rate happens tomorrow? © MHA MacIntyre Hudson 2014 Q&A Thank you for coming. Any questions? Contact: Tom Byng (Tax Partner) – [email protected] Ricky Noimark (Tax Manager) – [email protected] 0208 446 0922 www.macintyrehudson.co.uk Download ‘MHA tax app’ © MHA MacIntyre Hudson 2014 Disclaimer This information is based upon current legislation, which is subject to change. Whilst every effort has been made to provide accurate and up-to-date information, it is recommended that you consult us before taking, or refraining from taking, action based on matters discussed. We accept no liability for any loss suffered. MHA MacIntyre Hudson is a firm of Chartered Accountants, Tax and Business Advisers, regulated by the Institute of Chartered Accountants of England and Wales. MHA MacIntyre Hudson is a founder member firm of MHA, a UK wide association of Chartered Accountants, and a member of Baker Tilly International, a preeminent network of accountancy firms worldwide © MHA MacIntyre Hudson 2014