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Latest blog entries: a place in the sun

Accountancy Age 18 Sep 2008

The Big Four is the place to start a career and why HMRC's holiday home ruling has a sting in the tail. It's all in our latest blogs round-up

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Accounting hot,
E&Y hottest

It’s official: accounting is hot. That’s according to Business Week’s annual careers survey.
The Big Four take four of the top five places in the Best Places to Launch a Career 2008 league table. KPMG is knocked into fifth place by Goldman Sachs, with PwC third, Deloitte second and E&Y nabbing the top spot.

More surprising though is that despite talk of layoffs by the big firms elsewhere, the Big Four do so well. But it seems there is little link between career longevity and an organisation being a good place to start out. After all investment banks do well too.

accountingmatters.accountancyage.com

Holiday homes,
HMRC’s latest

The recent press release from HM Revenue & Customs in respect of holiday homes abroad is not necessarily the good news that many believe. It confirms that individuals who own holiday homes through companies will not suffer a benefit in kind tax liability due to the company asset being made available to them. The change in HMRC position applies to all years, including those in the past. The press release goes onto give details about mechanisms to recover taxes paid for past periods.
Clearly the concept of the relieving provision is a step in the right direction, especially if the change is backdated in the favour of the individual. So where is the ‘sting in the tail’?
HMRC sets outs the conditions that need to be satisfied for no benefit to arise.
One of the conditions is that the property owning company is owned directly by the individual in question (or his family).

This is important and may be overlooked by some taxpayers. HMRC have confirmed that the revised legislation is designed to avoid a charge where the taxpayer may have accidentally suffered one.

As such, indirect ownership of the company shares (e.g. via trusts) is not exempted by the new relieving legislation and the possibility of a benefit in kind will continue.

There is also the question of the extent that the foreign entity will be a company for the purposes of the exemption, because the legislation uses the term ‘company’ and not ‘body corporate’.

I suspect that there will be a good few years of uncertainty as to the extent that some of the more unusual (and exotic) foreign property ownership vehicles are a company for these purposes.

Richard Verge,
goodmanjones.net

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