BusinessUpdate

November 2014

In this issueRecent changes to employment taxesWe outline some of the recent changes to employment taxes that you should be aware of – page 2

Action on profit shiftingProposals to target multinationals that shift profits to low tax jurisdictions may increase the compliance burden – page 4

Our survey of entrepreneursWe look at the results of our survey of UK entrepreneurs: how confident are they about the coming year? – page 6

Business Update

Editor’s comment

Amendments to FRS 102 are a step in the right direction Page 8

International action on profit shifting Page 4

Recent changes to employment taxes Page 2

A round-up of recent HMRC consultations Page 1

Employee ownership: new opportunities for succession planning Page 7

Welcome to the November issue of Business Update, our regular newsletter for

business owners, company directors and their professional advisers.

We begin this issue with a round-up of some of the recent consultations that HMRC

has undertaken which might affect readers of Business Update. Our second article

looks more closely at one of these consultations in particular, as well as other

developments covering employment taxes.

Tax planning by multinational companies has become more sophisticated over recent

years and there are recommendations for reforms to international tax law to crack

down on international profit shifting. We outline the recommendations and warn such

organisations of the additional compliance burden this will bring.

Earlier this year we surveyed UK entrepreneurs, to sample their views on the UK as a

place to do business and their levels of confidence. We summarise some of the results

here.

It’s now easier to transfer ownership of a business to its employees, via a new

Employee Ownership Trust. We look at how this would work in practice.

Our final article considers amendments to FRS 102 in relation to debt and other

financing arrangements. The classification of certain debt products has now changed

to ‘basic’; we look at what this means in practice.

I hope you find this issue interesting and informative. Please do contact me or your

usual Saffery Champness partner if you would like more information on any of the

topics featured here.

John Shuffrey

Our survey of UK entrepreneurs Page 6

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November 2014

A round-up of recent HMRC

consultationsWhere legislative changes to the tax system are proposed, the government has committed to consult formally with individuals, practitioners and businesses. The aim is to ensure that any changes are well targeted and the likely impacts understood.

We are seeing an increasing number of consultations being published by HM Revenue & Customs (HMRC), and in this article we highlight some of the recent consultations affecting businesses and their employees.

Benefits and expenses

Following a review of employee benefits and expenses by the Office of Tax Simplification (OTS), four key areas of simplification are being considered by the government.

These proposals are expected to reduce the compliance burden for employers when it comes to reporting expenses and benefits.

Our article on page 2 outlines the proposed changes.

Introducing the concept of a ‘marketable security’

Following a review of the rules relating to employee share schemes, the OTS has recommended that individuals would be able to choose whether a tax charge arises at the time the securities are acquired or, if different, when they become marketable (ie when they can be sold for cash).

Employment-related securities and internationally mobile employees

Another change proposed by the OTS concerns the taxation of share plans held by internationally mobile employees (IMEs). The OTS recommended that the tax and National Insurance treatment of shares awarded to

IMEs should be more closely aligned with that of other forms of employment income, subject to the provisions of international social security agreements.

Currently, where income arises on a ‘chargeable event’, such as the exercise of options, the income is apportioned into periods of UK residence and non-UK residence for tax purposes, so that only the income attributable to periods of UK residence is charged to tax. For National Insurance contributions (NICs) purposes, however, the entire income is assessed to NICs, with no apportionment for periods of non-residence.

The consultation proposes to align the NIC treatment with the tax treatment, so that apportionment is possible to disregard the days the individual was not within the UK National Insurance system (either because they were not resident in the UK for NIC purposes, or were within another country’s social security system) by virtue of the provisions of an international social security agreement.

Employee shareholding vehicles

HMRC is considering implementing a proposal put forward by the OTS for a new ‘employee shareholding vehicle’.

Its aim is to enable companies to manage their employee share arrangements and create a market for employees’ shares, with less administrative burden and at a reduced cost compared with current ownership vehicles, such as Employee Benefit Trusts or Employee

Ownership Trusts (see page 7). The new vehicle is not designed to provide any further tax advantages over and above those available for existing models.

Views are sought on the level of demand for such a vehicle. Responses will determine the government’s next steps and a further consultation will be held to seek views on the detail.

The OTS recommended that the tax and National Insurance treatment of shares awarded to internationally mobile employees should be more closely aligned with that of other forms of employment income.

2

Business Update

Recent changes to

employment taxesOver recent months there have been a number of government consultations and other developments covering employment taxes. We summarise some of the key developments.

Expenses and benefits

In June 2014, HM Revenue & Customs (HMRC) issued four consultation documents, which closed for responses on 9 September. The consultations cover key areas of simplification that were recommended by the Office of Tax Simplification (OTS) and which, in the 2014 Budget, the government announced its commitment to take forward. Legislation is expected to be included in Finance Bill 2015. The four areas are:

y Replacing the dispensation regime with an exemption for qualifying expenses that are paid or reimbursed by employers. The government is therefore proposing that qualifying expenses reimbursed by employers will be exempt from income tax and National Insurance contributions (NICs), such that no P11D reporting will be required.

Whilst the legislation to implement this proposal may be in place by April 2015, it is likely that the new rules will come into force at the start of a later tax year (probably 2016/17) to allow employers and HMRC time to prepare.

y Abolition of the £8,500 threshold for lower paid employment and form P9D, so that all employees are taxed on benefits in kind on the same basis. However, the consultation does seek to ascertain whether there are particular groups of people or business who are adversely affected and who might need some protection.

y The introduction of a statutory exemption for “trivial” benefits in kind. Currently, although employers can apply to HMRC for agreement to exclude certain benefits from being reported on the basis that they

are trivial, the difficulty is that neither the legislation nor HMRC defines what counts as a trivial benefit.

y Voluntary payrolling of taxable expenses and benefits in kind. Some employers already payroll benefits under arrangements individually agreed with HMRC, but there is currently no legislative framework.

Travel and subsistence

At the end of July 2014 the government announced a two-stage review of the tax rules on travel and subsistence expenses. The first stage of the review is designed to improve the government’s understanding of the commercial realities of travel and subsistence payments, such as the circumstances in which employers pay travel and subsistence expenses and how tax and other factors

HMRC has announced that for employers with 50 or fewer employees,

automatic late filing penalties for RTI

submissions will be deferred until

6 March 2015.

3

November 2014

influence commercial decision making in this area. The government is expected to report back on its initial findings in the Autumn Statement.

In the second stage of the review, the government intends to establish a working group to assist in producing a new set of principles upon which the rules of a new travel and subsistence tax regime will be based. These principles will be based on the findings from the first stage of the review. The government intends to report on this at the 2015 Budget.

Employment status review

The OTS has also been tasked by the government to review the notoriously complex dividing line between employment and self-employment and to consider whether it is drawn in the right place and in the right way. A report back is expected at the 2015 Budget.

Tax-free childcare

A new tax-free childcare scheme is expected to replace the existing childcare voucher scheme in autumn 2015. Employees who are already in a current voucher scheme can remain in it until their child reaches the age of 15, should they so wish.

Under the new scheme, which will be administered by National Savings & Investments, eligible families will have 20% of their yearly childcare costs paid for by the government, up to £2,000 per child. One of the advantages of the new scheme is that it will be open to all single parents and couples who work eight or more hours per week. This includes the self-employed and those who pay for Ofsted-registered childcare for a child under the age of 12 (or 16 if the child is disabled). The employer, as well as the employee, will be able to pay into an employee’s childcare account under the new scheme.

Company car advisory fuel rates

HMRC’s advisory fuel rates applicable to journeys from 1 September 2014 are set out in Figure 1 and Figure 2 below. For one month following the date of change, employers may use the previous or the new rates. These rates are those at which an employer can reimburse an employee for business journeys in a company vehicle without any income tax or NICs charges arising. The rates can also be used for VAT recovery purposes, as long as valid VAT receipts are retained.

Hybrid cars are treated as either petrol or diesel cars for this purpose.

Late filing penalties under RTI

HMRC has announced that for employers with 50 or fewer employees, automatic late filing penalties for Real Time Information (RTI) submissions will be deferred until 6 March 2015. Larger employers are subject to the penalty regime from

6 October 2014. Employers should be aware that irrespective of this relaxation penalties may still currently apply for late payment of PAYE/NICs and for incorrect returns.

Late filing penalties are limited to one penalty per month irrespective of the number of returns filed late, as shown in Figure 3 below.

National Minimum Wage

The rates increased from 1 October 2014. These are shown in Figure 4 below.

The apprentice rate applies to apprentices aged 16 to 18 and those aged 19 or over who are in their first year. All other apprentices are entitled to the National Minimum Wage for their age.

Fig. 1

Engine size Petrol LPG

1,400 or less 14p 9p

1,401 cc to 2,000 cc

16p 11p

Over 2,000 cc 24p 16p

Fig. 2

Engine size Diesel

1,600 cc or less 11p

1,601 cc to 2,000 cc 13p

Over 2,000 cc 17p

Fig. 3

Number of employees

Monthly penalty

1-9 £100

10-49 £200

50-249 £300

250+ £400

Fig. 4

Age Hourly rate

21+ £6.50

18-20 £5.13

Under 18 £3.79

Apprentice rate £2.73

4

Business Update

International action on

profit shiftingAs tax planning by multinationals has become more sophisticated, gaps between domestic tax systems have become more apparent. In addition, the development of the digital economy has meant that businesses are more mobile than ever before. There are concerns that multinationals have been exploiting gaps in national tax laws to divert profits to low tax jurisdictions, where the business has little or no real activity, in order to minimise or eliminate corporation taxes.

The Organisation for Economic Co-operation and Development (OECD) is looking to tackle this issue through its Base Erosion and Profit Shifting (BEPS) Project, which aims to reform international tax rules to prevent tax avoidance.

The OECD is keen that its Model Tax Convention adequately deals with the gaps in tax law, to ensure that multinationals do not exploit tax treaties to benefit from double non-taxation. In July 2013, it published an Action Plan on BEPS, which proposed a number of changes to the international tax system, including:

y Reviewing the application of existing international tax rules to the digital economy (ie online businesses).

y Developing treaty anti-avoidance provisions to deal with hybrid entities and hybrid instruments.

y Developing recommendations for countries to deal with controlled foreign companies, interest deductibility, treaty abuse and hybrids.

y Improving information exchange, including spontaneous exchange in some cases.

y Improving dispute resolution mechanisms.

y Broadening the definition of permanent establishment, with particular focus on commissionaire distribution models.

y Amending the transfer pricing rules, including broadening the definition of intangibles, and documentation requirements.

y Developing recommendations for reporting business restructuring and tax planning arrangements.

y Developing a multilateral instrument under which countries can implement the Action Plan proposals.

The first set of reports and recommendations have been issued during the course of 2014.

The Action Plan and the reports do not propose any radical change, but instead rely on amending and strengthening existing mechanisms such as transfer pricing, controlled foreign company and permanent establishment rules.

The UK already has the framework in place around which the Action Plan is built. UK tax legislation specifically incorporates the OECD Transfer Pricing Guidelines, and HM Revenue & Customs (HMRC) states that it follows the commentary to the OECD Model Tax Convention when interpreting other areas of legislation. Any changes made to these will therefore automatically be dealt with in the UK.

However, changes to information exchange and improved dispute resolution would require amendment to UK domestic legislation and/or double tax agreements.

The Action Plan has been favourably received by government, and was endorsed by the G20, which includes the UK. HMRC has subsequently published the UK’s priorities in the BEPS Project, which again endorses the OECD Action Plan.

Country-by-country reporting

The overall objective of the BEPS initiative is to ensure that profits are taxed where economic activities generating the profits are performed and where value is created.

In order to give a better indication of the location of the economic activity of a multinational group, the OECD proposes a two-tiered reporting structure: a ‘master file’ providing high-level information about the global business, and local country files with information relating to each entity in the group (country-by-country reporting).

The master file would include details of the group’s organisational structure together with a description of its business, its intangibles, intercompany financial activities, transfer pricing policies, and its financial and tax positions.

5

November 2014

A model country-by-country reporting template was prepared in early 2014 and was approved by the G20 at their meeting in September. Under the model template, the following information is required for each entity on an annual basis:

y Place of effective management;

y Business activity;

y Revenue, taken from the statutory or audited financial statements of the company;

y Earnings before income tax;

y The total income tax paid to the authorities in the country of organisation in the relevant tax year;

y The total income tax paid to all other countries in the relevant tax year;

y Amount of withholding taxes paid on payment received from the other entities (excluding employment related withholding taxes);

y Stated capital and accumulated earnings, as reflected on the year end balance sheet;

y Number of employees;

y Total employee expenses;

y Book value of tangible assets, excluding cash and financial assets; and

y Intercompany payments of royalties, interest and service fees.

Reporting will commence from 1 January 2015, and the deadline for filing the template is expected to be one year from the tax year end of the parent company.

The extensive information and level of detail required will significantly increase the administrative and compliance burden for multinational companies, and will represent a significant expansion of information provided on a corporation tax return.

Companies will need to consider how they will prepare for the new reporting template, and existing data gathering and financial reporting systems may need to be reviewed and updated accordingly.

The extensive information and level of detail required will significantly increase the administrative and compliance burden for multinational companies.

6

Business Update

For 26% of respondents the availability of skilled labour was the biggest challenge.

The inaugural Saffery Champness survey of entrepreneurs carried out earlier this year revealed that UK entrepreneurs are largely confident about the future prospects for their businesses. Indeed over 84% of respondents to our survey were either very or quite confident that they would achieve their business objectives over the coming year. Only 5% were not particularly confident.

In terms of growth, 52% of respondents had increased their workforce over the past year and 67% of respondents had seen an increase in turnover.

Interestingly, 68% of those surveyed said they would be concentrating on organic growth over the coming year and had no intention of either selling or acquiring businesses. A quarter of those we surveyed did plan on making business acquisitions over the next 12 months.

To support their growth, 29% of respondents saw customers as key; believing that working with their customers was the most important way of fostering business innovation and growth. Employees were a very close second (28%). These results highlight the importance of effective customer and employee engagement – of maximising the resources that are actually very close to hand.

We asked those we surveyed about the most important challenges they faced in terms of the success of their business. For 27% of respondents the quality of the management team was fundamental. For 26% of respondents the availability of skilled labour was the biggest challenge. The economy was the most important challenge for 19% of respondents.

Interestingly, only 39% of those we surveyed believed that government incentives to encourage investment in small business are effective.

The entrepreneurs we surveyed also preferred more traditional forms of business funding. While only 7% had explored crowdfunding over the past year, 35% of entrepreneurs considered a bank loan as a means of funding their business and 28% had considered personal funding of their business over the past year.

Finally, we asked entrepreneurs how they would vote in a referendum on whether the UK should leave the EU: 17% said they would vote to leave. 53% of entrepreneurs believed that the UK’s relationship with Europe is important to the success of their business.

Our survey of UK

entrepreneurs

Employees are the key to innovation

and business growth.

28%

Not particularly

confident about

achieving their

objectives.

5%84%Very or quite confident

that they will achieve their

business objectives over

the next 12 months.

Said their workforce

increased by over 5%

over the past 12 months.

34%

Employee ownership: new opportunities for succession planning

7

November 2014

The Nuttall Review, published in 2013, highlighted how employee ownership can help companies become more successful by promoting greater commitment and productivity from their employees, who feel greater loyalty to a business in which they have a personal stake. Recognising the potential benefits, Finance Act 2014 introduced important new tax reliefs that should make it easier to transfer a company’s ownership to an Employee Ownership Trust (EOT).

The potential advantages of employee ownership are widely recognised, but the practical issues, in addition to tax implications, associated with transferring shares to a large number of employees have proved one of the greatest obstacles to a more widespread adoption of this model. One means of sidestepping the problem is to hold shares through a trust for the benefit of the employees and the reliefs introduced by Finance Act 2014 are intended to facilitate indirect share ownership.

Capital gains tax relief for sellers

From 6 April 2014, an individual disposing of shares to a qualifying EOT will be treated as making the disposal at nil gain, nil loss so that no capital gains tax (CGT) liability arises on the disposal, subject to a number of conditions:

y The shares must be in a trading company or the holding company of a trading group;

y The EOT must acquire a controlling interest during the tax year; and

y The taxpayer and connected persons must not have made a disposal of shares that qualified for this relief in an earlier tax year.

In addition to the CGT relief, the disposal of the shares into the EOT will be exempt

from any inheritance tax charges. There will however be a liability to Stamp Duty on the sale of the shares.

Income tax relief for employees

Since 1 October 2014, employees of companies owned by EOTs have been able to benefit from an income tax exemption in respect of bonus payments made to them of up to £3,600 per annum.

All employees with at least 12 months’ service must be entitled to benefit, but the company has discretion to set the amount of the bonus by reference to percentage of salary, length of service or hours worked. The payment must be a genuine bonus rather than part of the employee’s regular salary and there can be no arrangement in place for the employee to forego part of their salary in exchange for payment of a bonus.

The exemption relates to income tax only and Class 1 National Insurance contributions will still be payable on the bonus by both the employee and the employer.

Corporation tax

Any tax-free bonuses paid to employees will be deductible by the company in computing its corporation tax liability.

Qualifying trusts

To satisfy the conditions for relief, the EOT must be established for the benefit of all employees on the same terms. In addition, certain key participators must be excluded from being beneficiaries of the trust.

The EOT must hold more than 50% of the company’s ordinary share capital which carries more than 50% of the voting powers, rights to profit and assets available on a winding up.

A CGT charge may arise on the trust in the event that the qualifying conditions are breached.

Transitional rules apply which may enable existing Employee Benefit Trusts (EBTs) to qualify as EOTs.

Next steps

An EOT presents another option for business owners considering their exit strategy, particularly those who do not see themselves passing the business to the next generation of their family, and may be an attractive alternative to a trade sale or management buy-out.

However, there are practical considerations as to whether the new measures will work as intended, including whether the terms of the trust would unduly constrain the ability to raise funds to buy out the owner.

Our survey of UK

entrepreneurs

Amendments to FRS 102are a step in the right direction

8

Business Update

When the ‘new UK GAAP’ accounting standard, FRS 102, was originally published it was known that amendments would be made in relation to debt and other financing arrangements. The Financial Reporting Council (FRC) has now finalised its amendments to the classification of certain debt products. These changes will allow more of these items to be classified as ‘basic’, which eliminates the requirement for them to be fair-valued.

The FRC has also concluded on the accounting for hedging transactions. The amendments are practical with useful examples and in theory should make hedge accounting easier to achieve. These amendments are effective with the rest of the standard for accounting periods commencing on or after 1 January 2015.

The ‘basic’ principle

One of the fundamental principles within FRS 102 is that debt instruments must be classified into one of two camps; either basic or other. If an instrument meets the basic definition, it is held at amortised cost (loan principal minus repayments) on the balance sheet. If it fails to meet the definition, it must be held at fair value, with fair value movements taken through profit and loss (or ‘income statement’ in the new terminology).

The recent amendments to FRS 102 have expanded the criteria for classification as basic. This is seen as a positive change, as it means that many commonly occurring loan arrangements can continue to be presented in a similar manner to that under current UK GAAP, and without the added volatility of fair value movements going through the income statement. The criteria for classification as basic have been amended as follows:

y Interest rates on basic debt products may now include positive fixed or positive variable rates. They can also be a combination of a positive or a negative fixed rate and a positive variable rate. This would allow a product with an interest rate of LIBOR plus 200 basis points or LIBOR, less 50 basis points, to be classified as basic. However, an interest rate of 500 basis points, less LIBOR, would render a product non-basic, since the variable rate is negative.

y Loan repayments or interest rates (but not both) may be linked to a “single relevant observable index of general price inflation”, eg the Retail Price Index (RPI) or Consumer Price Index (CPI), in order to be classified as basic. However, an interest rate of five times RPI would breach the criteria because leverage of such rates is not permitted. Further, the index must be an index of general price inflation; the standard specifically identifies house price inflation as not being a measure of general price inflation, as it relates only to inflation for residential property.

y Other amendments allow for the interest rate of a basic instrument to vary over the life of the loan under certain conditions, for example a change in LIBOR. Provisions that permit the extension of the term of the loan are acceptable for the instrument to be classified as basic. However, any contractual provisions that could result in the holder losing the principal amount would render the product non-basic. The standard does clarify that debt subordinated to other debt is not such a provision.

y Finally, certain prepayment provisions or clauses to put the loan back to the issuer before maturity must not be contingent on future events (other than in specific circumstances, for example loan covenant violations), otherwise it will fall to be classified as non-basic. To be clear, if a provision is included in a loan agreement requiring compensation for early termination, it does not itself trigger a breach of this condition.

In a helpful addition to the standard, some illustrative examples are used to assist in the classification of financial instruments, see Figure 1.

9

November 2014

Hedging simplified

Many businesses mitigate common business risks, such as exposure to interest rate or foreign exchange movements, by utilising swap contracts or other derivatives. These arrangements are often known as hedging relationships.

A hedging relationship consists of:

y A hedged item, eg the risk of variability in interest payments on a variable rate loan or foreign exchange risk on a future forecast transaction; and

y A hedging instrument, eg an interest rate swap or a foreign exchange forward contract.

FRS 102 specifically requires most commonly occurring hedging instruments such as options, rights, futures and interest rate swaps to be accounted for as non-basic. They must therefore be held at fair value and revalued to fair value at each balance sheet date. This is true whether hedge accounting is applied or not and in many cases will result in a transitional adjustment upon transition to FRS 102. Fair value movements upon revaluation will introduce volatility into the income statement.

In many cases it may be possible, although it is optional, to account for the relationship as a hedge. The amendments to FRS 102 distinguish between two types of hedges (note that a net investment in a foreign operation would be accounted for similarly to a cash flow hedge):

y Fair value hedges, which reduce exposure to changes in the fair value of a financial statement item. An example would be a hedge against fair value movements on a non-basic debt instrument. Movements in the fair value of both the hedged item and the hedging instrument are recognised through the income statement in the same period. They will offset to the extent that the hedge is effective. This reduces volatility in the income statement caused by movements in the fair value of the hedged item.

y Cash flow hedges, which reduce exposure to variability in cash flows attributable to a financial statement item. An example would be a hedge against variability in interest payments on a variable rate loan. In a cash flow hedge, movements in the fair value of the hedging instrument are deferred through other comprehensive income. They are subsequently recycled

to the income statement when the hedged item is realised or a non-financial asset or liability is recognised. This effectively brings the recognition of the gain or loss on the hedging instrument into the same accounting period as the gain or loss on the hedged item, thus reducing volatility.

The mechanics of each type of swap are set out in some useful illustrative examples within the amendments to FRS 102.

The FRC has responded to feedback on the original drafting of FRS 102 in these areas and the result is practical and clear guidance on what is often seen as a complex area of accounting.

FRS 102 specifically requires most commonly occurring hedging instruments... to be accounted for as ‘non-basic’.

Example Classification

1. Zero-coupon loan Basic

2. Fixed interest rate loan which reverts to the bank’s standard variable interest rate. Basic

3. A loan with an interest payable at the bank’s standard variable rate plus 1%. Basic

4. A loan with interest payable at the bank’s standard variable rate less 1%, with the condition that the interest rate can never fall below 2%.

Basic

5. Interest on a loan is referenced to two times the bank’s standard variable rate. Non-basic

6. Interest on a loan is charged at 10% less six-month LIBOR over the life of the loan. Non-basic

7. Interest on a GBP denominated mortgage is linked to the UK Land Registry House Price Index (HPI) plus 3%. Non-basic

Fig. 1: examples of financial instruments and their classification explained within the amendments to FRS 102

Saffery Champness is regulated for a range of investment business activities by the Institute of Chartered Accountants in England and Wales. Saffery Champness is a member of Nexia International, a worldwide network of independent accounting and consulting firms. No responsibility for loss occasioned to any person acting on or refraining from action as a result of the material in this publication can be accepted by Saffery Champness. J5554.

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