Finance Act 2003 (c. 14)

(The document as of February, 2008)

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(b) is made in connection with the termination of the recipient's employment with the employer.

(2) In sub-paragraph (1)(a)--

"employment income tax charge" means a charge to tax under the Income Tax (Earnings and Pensions) Act 2003 (c. 1) (whether on the recipient or on someone else);
"NIC charge" means a liability to pay national insurance contributions under section 6 (Class 1 contributions), 10 (Class 1A contributions) or 10A (Class 1B contributions) of the Contributions and Benefits Act.

(3) The conditions mentioned in sub-paragraph (1)(a) are--

(a) that the duties of the employment in respect of which the payment or transfer was made were performed in the United Kingdom, and

(b) that the person in respect of whose employment the payment or transfer was made fulfilled at all relevant times the conditions as to residence or presence in Great Britain or Northern Ireland prescribed under section 1(6)(a) of the Contributions and Benefits Act.

(4) In this paragraph "the Contributions and Benefits Act" means--

(a) the Social Security Contributions and Benefits Act 1992 (c. 4), or

(b) the Social Security Contributions and Benefits (Northern Ireland) Act 1992 (c. 7).

(5) Where the provision of a qualifying benefit takes the form of the payment of money, the benefit is treated for the purposes of this Schedule as provided at the time when the money is treated as received for the purposes of Chapter 4 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003, applying the rules in section 18 of that Act (receipt of money earnings).

"Qualifying expenses"

3 In this Schedule "qualifying expenses"--

(a) does not include expenses that, if incurred by the employer, would not be deductible in calculating for tax purposes the employer's profits for any period, but

(b) subject to that, includes any expenses of the third party (other than the provision of benefits to employees of the employer) in operating the employee benefit scheme in question.

Payment "out of" employee benefit contributions

4 (1) For the purposes of paragraph 1(3)(a) any qualifying benefits provided or qualifying expenses paid by the third party after the receipt by him of employee benefit contributions are regarded as being provided or paid out of those contributions, up to the total amount of the contributions as reduced by the amount of any benefits or expenses previously provided or paid as mentioned in paragraph 1(3)(a).

(2) For the purposes of paragraph 1(4)(a) any qualifying benefits provided by the third party after the receipt by him of employee benefit contributions are regarded as being provided out of those contributions, up to the total amount of the contributions as reduced by the amount of any benefits or expenses previously provided or paid as mentioned in paragraph 1(3)(a) or (4)(a).

(3) In applying sub-paragraphs (1) and (2) above no account shall be taken of any other amount received or paid by the third party.

Transfer of asset to employee

5 (1) This paragraph applies where the provision of a qualifying benefit takes the form of the transfer of an asset.

(2) The amount provided shall be taken for the purposes of this Schedule to be the total of--

(a) the amount (if any) expended on the asset by the third party, and

(b) in a case where the asset was transferred to the third party by the employer, the amount of the deduction that would be allowed as mentioned in paragraph 1(1) in respect of the transfer.

(3) But where the amount given by sub-paragraph (2) above is more than the amount that is charged to tax under the Income Tax (Earnings and Pensions) Act 2003 (c. 1) in respect of the transfer, or would be so charged if the condition in paragraph 2(3)(a) were met, the deduction allowable under paragraph 1(3) or (4) is limited to that lower amount.

Provisional calculation of profits

6 Where the calculation referred to in paragraph 1(1) is made before the end of the nine-month period mentioned in paragraph 1(3)--

(a) for the purposes of making the calculation, paragraph 1(3) shall be read as if the reference to that nine-month period were a reference to the period ending at the time when the calculation is made, but

(b) after the end of the nine-month period the calculation shall if necessary be adjusted to take account of any benefits provided, expenses paid or contributions made within that period but after the time of the calculation.

Life assurance business

7 (1) In the case of an insurance company carrying on life assurance business, the effect of section 86 of the Finance Act 1989 (c. 26) (spreading of relief for acquisition expenses) shall be ignored in determining for the purposes of paragraph 1(1) whether a deduction would (apart from this Schedule) be allowed for a particular period.

(2) But paragraph 1(4) has effect subject to that section where, in accordance with sub-paragraph (1) above, an amount is allowed as a deduction for a particular period under paragraph 1(4).

Deductions to which Schedule does not apply

8 This Schedule does not apply to any deduction that is allowable--

(a) in respect of anything given as consideration for goods or services provided in the course of a trade or profession,

(b) in respect of contributions under a retirement benefits scheme within the meaning of Chapter 1 of Part 14 of the Taxes Act 1988 (see section 611 of that Act),

(c) in respect of contributions under a personal pension scheme approved under Chapter 4 of that Part (see section 630 of that Act),

(d) in respect of contributions under an accident benefit scheme,

(e) under Schedule 4AA to that Act (approved share incentive plans),

(f) under section 67 of the Finance Act 1989 (c. 26) (qualifying share ownership trusts), or

(g) under Schedule 23 to this Act (relief for employee share acquisition).

Interpretation

9 (1) In this Schedule--

"accident benefit scheme" means an employee benefit scheme under which benefits may be provided only by reason of a person's disablement, or death, caused by an accident occurring during his service as an employee of the employer;
"employee benefit contribution" shall be read in accordance with paragraph 1(2);
"employee benefit scheme" means a trust, scheme or other arrangement for the benefit of persons who are, or include, employees of the employer;
"the employer" shall be read in accordance with paragraph 1(1);
"for tax purposes" means for any purposes of income tax or corporation tax;
"qualifying benefits" shall be read in accordance with paragraph 2;
"qualifying expenses" has the meaning given by paragraph 3;
"the third party" shall be read in accordance with paragraph 1(2).

(2) A reference in this Schedule to a person's employee includes a reference to the holder of an office under that person, and "employment" shall be read accordingly.

Consequential amendments

10 (1) In section 43 (Schedule D) and section 44 (investment and insurance companies) of the Finance Act 1989 (c. 26), in subsection (2) (amounts charged in accounts in respect of employees' remuneration) for paragraphs (a) and (b) substitute "for which provision is made in the accounts".

(2) In Schedule 29 to the Finance Act 2002 (c. 23) (intangible fixed assets), in paragraph 113(3)(a) (meaning of "potential emoluments") omit the words "or benefits" and ", or held by an intermediary,".

Commencement and transitory provisions

11 (1) This Schedule has effect in relation to deductions that would (but for this Schedule) be allowed for a period ending on or after 27th November 2002 in respect of employee benefit contributions made on or after that date.

(2) In relation to any time before the coming into force of the Income Tax (Earnings and Pensions) Act 2003 (c. 1), this Schedule has effect as if--

(a) the references to tax under that Act were to income tax under Schedule E;

(b) the reference in paragraph 8(e) to Schedule 4AA to the Taxes Act 1988 (approved share incentive plans) were to Part 12 of Schedule 8 to the Finance Act 2000 (c. 17) (employee share ownership plans);

(c) for the words in paragraph 2(5) from "treated as received" to the end there were substituted "treated as received for the purposes of section 202A(1)(a) of the Taxes Act 1988, applying the rules in section 202B(1) to (6) of that Act (receipts basis of assessment for Schedule E)".

(3) In relation to any such time, sections 43(11)(a) and 44(9)(a) of the Finance Act 1989 have effect with the omission of the words "or benefits" and ", or held by an intermediary,".

(4) In relation to a period beginning before 1st January 2003, the reference in paragraph 8(g) to a deduction allowable under Schedule 23 to this Act shall be read as a reference to a deduction allowable to a company for that period in respect of a person--

(a) acquiring shares that are qualifying shares within the meaning of that Schedule, or

(b) having a right to acquire such shares,

whether in that period or subsequently, by reason of his or another's employment with the company.

Section 149(3)

SCHEDULE 25 Determination of profits attributable to permanent establishment: supplementary provisions

The Schedule inserted in the Taxes Act 1988 as Schedule A1 is as follows--

" SCHEDULE A1 Determination of profits attributable to permanent establishment: supplementary provisions

Part 1 Introduction

Introduction

1 (1) The provisions of this Schedule have effect for supplementing section 11AA as regards the determination of the profits attributable to a permanent establishment in the United Kingdom of a company that is not resident in the United Kingdom ("the non-resident company").

(2) In this Schedule "the separate enterprise principle" means the principle in section 11AA(2) (read with subsection (3) of that section).

Part 2 General provisions

Transactions treated as taking place at arm's length

2 In accordance with the separate enterprise principle, transactions between the permanent establishment and any other part of the non-resident company are treated as taking place on such terms as would have been agreed between parties dealing at arm's length.

Application of general provision as to allowable deductions

3 (1) Section 11AA(4) (general provision as to allowable deductions) applies whether or not the expenses are incurred by, or reimbursed by, the permanent establishment.

(2) The amount of expenses to be taken into account under section 11AA(4) is the actual cost to the non-resident company.

Prohibition of deductions for payments in respect of intangible assets

4 (1) No deduction is allowed in respect of royalties paid, or other similar payments made, by the permanent establishment to any other part of the non-resident company in respect of the use of intangible assets held by the company.

(2) This does not prevent a deduction in respect of any contribution by the permanent establishment to the costs of creation of an intangible asset.

(3) In this paragraph "intangible asset" has the meaning it has for accounting purposes, and includes any intellectual property (as defined in paragraph 2(2) of Schedule 29 to the Finance Act 2002).

Prohibition of deductions for interest or other financing costs

5 (1) No deduction is allowed in respect of payments of interest or other financing costs by the permanent establishment to any other part of the non-resident company, except as provided by sub-paragraph (2).

(2) The restriction in sub-paragraph (1) above does not apply to interest or other costs of financing that are payable in respect of borrowing by the permanent establishment in the ordinary course of a financial business carried on by it.

(3) In sub-paragraph (2) "financial business" means any of the following--

(a) banking, deposit-taking, money-lending or debt-factoring, or a business similar to any of those;

(b) dealing in commodity or financial futures.

Provision of goods or services for permanent establishment

6 (1) This paragraph applies where the non-resident company provides the permanent establishment with goods or services.

(2) If the goods or services are of a kind that the company supplies, in the ordinary course of its business, to third parties dealing with it at arm's length, the matter is dealt with as a transaction to which the separate enterprise principle applies.

(3) If not, the matter is dealt with as an expense incurred by the non-resident company for the purposes of the permanent establishment.

Part 3 Provisions applicable to non-resident banks

Application of this Part

7 (1) The provisions of this Part of this Schedule have effect where the non-resident company is a bank.

"Bank" for this purpose has the meaning given by section 840A.

(2) Nothing in this Part of this Schedule shall be read as preventing the application of principles similar to those provided for in this Part in applying the separate enterprise principle to a non-resident company that is not a bank.

Non-resident banks: transfer of financial assets

8 (1) In accordance with the separate enterprise principle, transfers of loans and other financial assets between the permanent establishment and any other part of the company are recognised only if they would have taken place between independent enterprises.

(2) Such a transfer is not recognised where it cannot reasonably be considered that it is carried out for valid commercial reasons.

For this purpose the obtaining of a tax advantage is not a valid commercial reason.

Loans by non-resident banks: attribution of financial assets and profits arising

9 (1) In accordance with the separate enterprise principle, loans and other financial assets, and profits arising from them, are attributed to a permanent establishment to the extent that they can reasonably be regarded as having been generated by the activities of the permanent establishment.

(2) The following provisions have effect as regards the factors to be taken into account.

(3) Particular account shall be taken of the extent to which the permanent establishment is responsible for--

(a) obtaining the offer of new business;

(b) establishing the potential borrower's credit rating and the risk involved in providing credit;

(d) deciding whether, and if so on what conditions, to make or extend the loan.

(4) Account may also be taken of the extent to which the permanent establishment is responsible for--

(a) concluding the loan agreement and disbursing the proceeds of the loan;

(b) administering the loan (including handling and monitoring the service of it) and holding and controlling any securities pledged.

(5) References in this paragraph to a financial asset include any financial risk in relation to a loan, or potential loan, that is capable of giving rise to fees or other receipts and for which the holding of capital is required (or would be required if the transaction were between parties at arm's length).

Borrowing by non-resident banks: permanent establishment acting as agent or intermediary

10 (1) This paragraph applies where a permanent establishment--

(a) borrows funds for the purposes of another part of the non-resident company, and

(b) in relation to that borrowing acts only as an agent or intermediary.

(2) In such a case, in accordance with the separate enterprise principle--

(a) the profits attributable to the permanent establishment, and

(b) the capital attributable to the permanent establishment under section 11AA(3),

shall be that appropriate in the case of an agent acting at arm's length, taking into account the risks and costs borne by the establishment. " .

Section 152

SCHEDULE 26 Non-resident companies: transactions through broker, investment manager or Lloyd's agent

Introduction

1 (1) This Schedule makes provision about transactions carried out on behalf of a company that is not resident in the United Kingdom (a "non-resident company"), in the course of that company's trade, by a person in the United Kingdom acting as--

(a) a broker (paragraph 2),

(b) an investment manager (paragraphs 3 to 5), or

(2) The provisions of this Schedule supplement--

(a) section 148(3) (meaning of "permanent establishment": not to include independent agent), and

(b) section 151(2)(c) (limit on income tax chargeable on non-resident company: income arising from transactions carried out through independent agent).

Brokers

2 (1) In relation to a transaction carried out on behalf of a non-resident company, a broker is regarded as an agent of independent status acting in the ordinary course of his business if, and only if, the following conditions are met.

(2) The conditions are--

(a) that at the time of the transaction he is carrying on the business of a broker;

(b) that the transaction is carried out by him in the ordinary course of that business;

(c) that the remuneration he receives in respect of the transaction for the provision of the services of a broker to the non-resident company is not less than is customary for that class of business; and

(d) that he does not fall to be treated as a permanent establishment of the non-resident company in relation to any other transaction carried out in the same accounting period.

Investment managers

3 (1) In relation to an investment transaction carried out on behalf of a non-resident company by a person providing investment management services (an "investment manager"), the investment manager is regarded as an agent of independent status acting in the ordinary course of his business if, and only if, the following conditions are met.

(2) The conditions are--

(a) that at the time of the transaction he is carrying on a business of providing investment management services;

(b) that the transaction is carried out in the ordinary course of that business;

(d) that the requirements of the 20% rule are met (see paragraph 4);

(e) that the remuneration he receives in respect of the transaction for the provision to the non-resident company of investment management services is not less than is customary for that class of business; and

(f) that he does not fall to be treated as a permanent establishment of the company in relation to any other transaction carried out in the same accounting period.

(3) In sub-paragraph (1) "investment transaction" means--

(a) transactions in shares, stock, futures contracts, options contracts or securities of any description not mentioned in this paragraph, but excluding futures contracts or options contracts relating to land,

(b) transactions consisting in the buying or selling of any foreign currency or in the placing of money at interest, and

Regulations for the purposes of paragraph (c) shall be made by statutory instrument which shall be subject to annulment in pursuance of a resolution of the House of Commons.

(4) For the purposes of sub-paragraph (3) a contract is not prevented from being a futures contract or an options contract by the fact that any party is or may be entitled to receive or liable to make, or entitled to receive and liable to make, only a payment of a sum (as opposed to a transfer of assets other than money) in full settlement of all obligations.

Investment managers: the 20% rule

4 (1) The requirements of the 20% rule are--

(a) that in relation to a qualifying period (see sub-paragraph (2)) it has been or is the intention of the investment manager and the persons connected with him that the company's relevant excluded income (see sub-paragraph (3)) should, as to at least 80%, consist of amounts to which neither he nor any such person has a beneficial entitlement (see sub-paragraph (4)), and

(b) to the extent that there is a failure to fulfil that intention, that failure--

(i) is attributable (directly or indirectly) to matters outside the control of the investment manager and persons connected with him, and

(ii) does not result from a failure by him or any of those persons to take such steps as may be reasonable for mitigating the effect of those matters in relation to the fulfilment of that intention.

(2) A "qualifying period" means--

(a) the accounting period in which the transaction in question is carried out, or

(b) a period of not more than five years comprising two or more complete accounting periods including that one.

(3) The "relevant excluded income" of a non-resident company for a qualifying period is the aggregate of such of the chargeable profits of the company for the accounting periods comprised in the qualifying period as derive from transactions carried out by the investment manager on the company's behalf in relation to which the manager does not (apart from the requirements of the 20% rule) fall to be treated as a permanent establishment of the company.

(4) A person has a "beneficial entitlement" to relevant excluded income if he has or may acquire a beneficial entitlement by virtue of--

(a) an interest of his (whether or not an interest giving a right to an immediate payment of a share in the profits or gains) in property in which the whole or any part of that income is represented, or

(b) an interest of his in or other rights in relation to the non-resident company,

that is or would be attributable to that income.

(5) In the case of a transaction in relation to which the conditions in paragraph 3 are met except for the requirements of the 20% rule, this Schedule has effect as if the requirements of that rule were met in relation to so much of the chargeable profits of the non-resident company deriving from the transaction as do not represent relevant excluded income of the company to which the investment manager or a person connected with him has or has had any beneficial entitlement.

Investment managers: application of 20% rule to collective investment schemes

5 (1) This paragraph applies where amounts arise or accrue to the non-resident company as a participant in a collective investment scheme.

(2) The requirements of the 20% rule need not be met in relation to a transaction carried out for the purposes of the scheme if the scheme is such that, if the following assumptions applied--

(a) that all transactions carried out for the purposes of the scheme were carried out on behalf of a company constituted for the purposes of the scheme and resident outside the United Kingdom, and

(b) that the participants did not have any rights in respect of the amounts arising or accruing in respect of those transactions other than the rights that, if they held shares in the company on whose behalf the transactions are assumed to be carried out, would be their rights as shareholders,

the assumed company would not, in relation to the accounting period in which the transaction was carried out, be regarded for tax purposes as carrying on a trade in the United Kingdom.

(3) Where on those assumptions the assumed company would be regarded for tax purposes as carrying on a trade in the United Kingdom, paragraph 4 has effect with the following modifications in relation to a transaction carried out for the purposes of the scheme--

(a) for references to the non-resident company substitute references to the assumed company;

(b) for references to the non-resident company's relevant excluded income substitute references to the aggregate of the amounts that would, for accounting periods comprised in the qualifying period, be chargeable to tax on the assumed company as profits deriving from the transactions carried out by the investment manager and assumed to be carried out on behalf of the company.

(4) In this paragraph "collective investment scheme" has the meaning given by section 235 of the Financial Services and Markets Act 2000 (c. 8), and "participant", in relation to such a scheme, shall be construed in accordance with that section.

Lloyd's agents

6 (1) Where a non-resident company is a member of Lloyd's and the transaction is carried out in the course of the company's underwriting business, a person who acts on behalf of the company in relation to the transaction is regarded as an independent agent acting in the ordinary course of his business if he acts as members' agent or as managing agent of the syndicate in question.

(2) In sub-paragraph (1)--

(a) the reference to the non-resident company being a member of Lloyd's is to its being a corporate member within the meaning of Chapter 5 of Part 4 of the Finance Act 1994 (c. 9); and

(b) the references to a members' agent and to a managing agent shall be construed in accordance with section 230 of that Act.

General supplementary provisions

7 (1) For the purposes of this Schedule a person is regarded as carrying out a transaction on behalf of another where he undertakes the transaction himself, whether on behalf of or to the account of that other, and also where he gives instructions for it to be so carried out by another.

(2) For the purposes of this Schedule a person is regarded as acting in an independent capacity on behalf of a company only if the relationship between them, having regard to its legal, financial and commercial characteristics, is a relationship between persons carrying on independent businesses that deal with each other at arm's length.

(3) Section 839 of the Taxes Act 1988 (connected persons) applies for the purposes of this Schedule.

(4) This Schedule has effect in the case of a person who acts as a broker or provides investment services as part only of a business as if that part were a separate business.

Section 155

SCHEDULE 27 Permanent establishment etc: consequential amendments

Taxes Act 1988

1 (1) The Taxes Act 1988 is amended as follows.

(2) In section 606 (persons responsible in case of default of administrator of retirement benefits scheme), for subsection (13) substitute--

" (13) References in this section to the employer include, where the employer is not resident in the United Kingdom, any person who is treated as UK representative of the employer under section 126 of the Finance Act 1995 or section 150 of the Finance Act 2003. " .

(3) In section 806L (carry forward or carry back of unrelieved foreign tax), for subsection (7) substitute--

" (7) In this section--

"overseas permanent establishment" means a permanent establishment through which a company carries on a trade in a territory outside the United Kingdom; and
"permanent establishment"--
(a)
if there are arrangements having effect under section 788 in relation to the territory concerned that define the expression, has the meaning given by those arrangements, and
(b)
if there are no such arrangements, or if they do not define the expression, has the meaning given by section 148 of the Finance Act 2003. " .

(4) In Schedule 15 (qualifying policies), in paragraph 24 (policies issued by non-resident companies), in sub-paragraph (3)(b) (twice) and (c) for "branch" substitute "permanent establishment".

Taxation of Chargeable Gains Act 1992

2 (1) The Taxation of Chargeable Gains Act 1992 (c. 12) is amended as follows.

(2) In section 10 (non-resident with United Kingdom branch or agency)--

(a) omit subsection (3); and

(b) in subsection (4), omit "or corporation tax".

(3) In sections 13(5)(d), 25(7)(b), 106(10), 139(1A), 140A(2), 159(4)(b), 171(1A), 175(2AA), 179(1A), 190(2)(b) and (3)(b), 199(6)(b) and 228(6)(b), and in Schedule 7A, paragraph 1(3A), for "10(3)" substitute "10B".

Finance Act 1993

3 (1) In sections 93 and 93A of the Finance Act 1993 (c. 34) (use of currency other than sterling) for "branch", wherever occurring, substitute "permanent establishment".

(2) The provisions in which the above amendment is to be made are--

(a) in section 93, subsection (2)(b) and the definition of "return of accounts" in subsection (7) (twice);

(b) in section 93A, subsections (2)(b), (3)(b) and (7)(b).

Finance Act 1995

4 (1) Section 126 of the Finance Act 1995 (c. 4) (UK representatives of non-residents) is amended as follows.

(2) In subsection (1), omit the words ", corporation tax".

(3) In subsection (2)--

(a) after paragraph (b) insert "and";

(b) in paragraph (c) omit the words from "or fall" to "non-resident"; and

(4) For subsection (8) substitute--

" (8) In this section, "branch or agency" means any factorship, agency, receivership, branch or management. " .

(5) In subsection (9), omit paragraph (b) and the word "and" preceding it.

(6) After subsection (9) insert--

" (10) This section does not apply in relation to income tax chargeable on income of a company otherwise than as a trustee. " .

5 (1) Section 127 of the Finance Act 1995 (persons not treated as UK representatives) is amended as follows.

(2) In subsection (1) for "(a) to (d)" substitute "(a) to (c)".

(3) In subsection (5)(b) omit "or 129".

(4) In subsection (17), in the definition of "branch or agency" for "the Management Act" substitute "section 126 above".

(5) In subsection (19) omit paragraph (b) and the word "and" preceding it.

6 In section 128 of the Finance Act 1989 (limit on income chargeable on non-residents: income tax), after subsection (11) insert--

" (12) This section does not apply in relation to income tax chargeable on income of a company otherwise than as a trustee. " .

7 Omit section 129 of the Finance Act 1995 (c. 4) (limit on income chargeable on non-residents: corporation tax).

Finance Act 1996

8 In Schedule 15 to the Finance Act 1996 (c. 8) (loan relationships: transitional provisions), in paragraph 8(6)(c)--

(a) for "10(3)" substitute "10B", and

(b) for "on a disposal by a branch or agency" substitute "attributable to a permanent establishment".

Finance Act 2000

9 In Schedule 15 to the Finance Act 2000 (c. 17) (corporate venturing scheme), in paragraph 79(5) (gain accruing on chargeable event), for "section 10" substitute "section 10B".

Section 159

SCHEDULE 28 Capital gains tax: reporting limits and annual exempt amount

Part 1 Reporting limits

1 After section 3 of the Taxation of Chargeable Gains Act 1992 (c. 12) insert--

" 3A Reporting limits

(1) Where in the case of an individual--

(a) the amount of chargeable gains accruing to him in any year of assessment does not exceed the exempt amount for that year, and

(b) the aggregate amount or value of the consideration for all chargeable disposals of assets made by him in that year does not exceed four times the exempt amount for that year,

a statement to that effect is sufficient compliance with so much of any notice under section 8 of the Management Act as requires information for the purposes of establishing the amount in which he is chargeable to capital gains tax for that year.

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