March 2019 / United Kingdom

The Individual Savings Account (Amendment regulations) Regulations were made on 26 February 2019. The Regulations increase the amount that can be subscribed to a Junior Individual Savings Account (a tax-advantaged savings product for children) from GBP 4,260 to GBP 4,368. The Regulations come into force on 6 April 2019.

According to an update of 5 March 2019, published by the HRMC, the Lesotho - United Kingdom Income Tax Treaty (2016) entered into force on 18 September 2018. The treaty generally applies from: In Lesotho:

• 1 November 2018: for withholding taxes; and
• 1 April 2019: for other taxes.

In the United Kingdom:

• 1 November 2018: for withholding taxes;
• 1 April 2019: for corporation taxes; and
• 6 April 2019: for income and capital gains taxes.

In Lesotho and the United Kingdom:

• 18 September 2018: for the provisions of article 24 (Mutual Agreement Procedure), article 25 (Exchange of Information), and article 26 (Assistance in the Collection of Taxes).

From these dates, the new treaty generally replaces the Lesotho - United Kingdom Income Tax Treaty (1997). Details of the new treaty will be reported subsequently.

According to information published by the Austrian government, the Austria - United Kingdom Income Tax Treaty (2018) entered into force on 1 March 2019. The treaty generally applies from: In Austria:

• 1 January 2020.

In the United Kingdom:

• 1 April 2019: for corporation taxes; and
• 6 April 2019: for income and capital gains taxes.

In Austria and the United Kingdom:

• 1 March 2021: for cases falling within paragraph 5 of article 23 (Mutual Agreement Procedure).

From these dates, the new treaty generally replaces the Austria - United Kingdom Income Tax Treaty (1969), as amended by the 1977, 1993 and 2009 protocols. In addition, notwithstanding the entry into force of the new treaty, an individual who is entitled to the benefits of article 21 (Teachers) of the 1969 treaty at the time of entry into force of the new treaty shall continue to be entitled to such benefits as if the 1969 treaty had remained in force.

Further to the report on 30 January 2019, the Chancellor of the Exchequer presented his Spring Statement 2019 to Parliament on 13 March 2019. Pursuant to the Statement, the following consultations were launched on 13 March 2019:

• a consultation on infrastructure finance which seeks to ensure high levels of private investment on UK infrastructure projects. The consultation runs to 5 June 2019;
• a consultation on the key features of the Structures and Buildings Allowance (draft secondary legislation), presented at the Budget 2018, which seeks to support business investment to develop new structural assets and enhance tax reliefs in relation to those assets. The consultation runs to 24 April 2019;
• a consultation on the new energy efficiency scheme for SMEs which runs to 8 May 2019; and
• a consultation on the decommissioning industry, seeking views from interested parties on how the UK decommissioning industry should work and how to encourage domestic industry to export its expertise abroad, making the United Kingdom a leading hub for decommissioning. The consultation runs to 8 May 2019.

The Chancellor added that the consultation on helping businesses to improve the way they use energy had been concluded on 26 September 2018. The following relevant publications were also announced by the Chancellor:

• the Tackling tax avoidance, evasion and other forms on non-compliance policy paper. The paper details HMRC strategy and approach to compliance for different taxpayers in order to ensure that all the taxpayers pay their fair share of tax;
• the No Safe Havens 2019 strategy. The strategy develops the HRMC objectives to fight against tax avoidance and tax evasion in offshore locations;
• the Unlocking digital competition report of the Digital Competition Expert Panel. The report includes recommendations made to improve the United Kingdom's competition framework on the digital markets (in the United Kingdom and internationally); and
• the Review of the Aggregates Levy discussion paper. The Aggregates Levy is an environmental tax implemented to reduce the extraction of fresh aggregate (rock, sand and gravel as bulk fill in construction). The government seeks a review of the Aggregates Levy in order to do potential reforms to improve its effectiveness.

On 26 March 2019, HM Treasury published a report on disguised remuneration schemes and the government's measures to counter them.

Research and Development (R&D) tax reliefs, including the small or medium-sized enterprise (SME) scheme, offer an incentive for businesses to invest. Budget 2018 announced measures to limit the amount of payable R&D tax credit that a qualifying loss-making business can receive in any one accounting period. On 28 March 2019, HMRC launched a consultation on the application of this limit. The consultation runs to 24 May 2019.