15 December 2016

Law firm clients: UK Government publishes draft Finance Bill 2017 clauses

The UK Government has published extracts of its draft Finance Bill for 2017 with proposed changes that would affect international assignees moving to the UK or returning from abroad, including:

— The abolition from April 6, 2018, of special relief granted to internationally mobile employees receiving certain termination payments known as "foreign service relief"

— An extension from April 6, 2017, of the scope of UK tax charges on pension income and lump-sum payments to UK residents from non-UK pension schemes, so that, in many cases, these payments will be subject to UK tax in full

— A new minimum 10-year period (formerly five years) during which employees who benefit from tax relief in respect of a non-UK pension scheme during a UK assignment must leave the UK to avoid UK tax charges on unapproved payments and on certain lump-sum payments from the scheme following their departure

— Restrictions, beginning April 5, 2017, on the ability of long-term UK residents, or individuals born in the UK with a UK domicile, to benefit from reduced tax charges on overseas income

Most of these changes are highly technical and law firms should consider what support or guidance to provide to their affected associates and partners.

Law firms should carefully consider the effect of the new rules on assignment costs for equalized individuals and also consider what communication and guidance they should provide to affected individuals who pay their own UK taxes.

In particular, the increased scope of UK tax on termination payments, pension benefits, and benefits in kind warrant careful consideration. For details, see Tax Alert 2016-2078.

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Contact Information
For additional information concerning this Alert, please contact:
 
Law Firm Industry Practice
Pankaj Khosla(212) 773-3226

Document ID: 2016-2143