Autumn Statement - Analysis

Related Party Rules –
partnerships and transfers of
intangible assets:
The intangible fixed asset rules are to be
amended, with regards to the tax
treatment on transfers of assets to
partnerships. The intention is to ensure
that partnerships cannot be used in
arrangements that seek to obtain a tax
relief for their corporate members in a
way that is contrary to the intention of
the regime. This change has immediate
effect. A more thorough review of the
intangible assets regime is also being
considered.
Rules for addressing hybrid
mismatch arrangements:
New legislation is to be introduced with
effect from 1 January 2017 to implement
the agreed OECD rules for addressing
hybrid mismatch arrangements. The new
rules will prevent multinational
enterprises avoiding tax through the use
of certain cross-border business
structures or finance transactions.
Taxation of asset manager’s
performance-based rewards
Legislation is to be introduced to
determine when performance awards
received by asset managers will be
taxed as income or capital gains – an
award will be subject to income tax,
unless the underlying fund undertakes
long term investment activity.
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