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July 09, 2020

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UK General Election – Finance Bill No.2 2017 Curtailed - Budget and Finance Bill

The UK Finance (No.2) Bill received Royal Assent on 27 April 2017, becoming the Finance Act 2017. However, as a result of Theresa May calling a general election for 8 June 2017, a large number of provisions in Finance Bill 2017 were dropped as a result of lack of Parliamentary time to consider properly the draft legislation. It is expected that those provisions that have been removed will be re-introduced following the election, depending, however, to some extent on which political party forms the next Government. The current Government stated that it intended to legislate "at the earliest opportunity" at the start of the new Parliament for the draft items that were not included in the final Finance Act.

The original draft provisions that were not enacted include the following:

  • The reduction in the nil rate of dividend taxation from £5,000 to £2,000

  • Amendments to the taxation of employment termination payments

  • Amendments to provisions relating to Venture Capital Schemes, EIS and SEIS

  • Corporation tax carried–forward loss restrictions*

  • Restrictions on corporate interest relief*

  • Amendments to substantial shareholding exemption*

  • Extension of disguised remuneration rules to self-employed earners*

  • Penalties for enablers of defeated tax avoidance

© 2020 Proskauer Rose LLP. National Law Review, Volume VII, Number 136


About this Author

Stephen Pevsner UK Tax law partenr Proskauer Rose private fund formation eorganisations, structured finance, investment funds

Stephen Pevsner is a tax partner and a member of the Private Investment Funds and Private Equity M&A groups. Stephen's practice covers the broad range of corporate and individual tax advice, with particular emphasis on private fund formation across a wide range of buyout, debt and infrastructure asset classes, as well as UK and international M&A transactions (often private equity backed). He has wide experience in corporate reorganisations, structured finance, investment funds and new business set-ups, and also advises regularly on a wide range of employee and fund manager...

Robert Gaut, Proskauer Rose, UK Tax Lawyer, Investment Attorney, Finance

Robert Gaut is a tax partner and head of our UK tax practice in London.

He has represented many of the world’s preeminent multinational corporations, sovereign wealth funds, investment banks and private equity funds on a full range of UK and international tax strategies relating to inbound and outbound transactions, capital markets offerings, establishment of investment funds and financing matters.

Recent representative transactions include:

  • Advising Ares Management LP, the leading global alternative asset manager, on the international tax aspects of its initial public offering, raising US$216 million in the first IPO by a major private equity firm since the Carlyle Group went public in 2012

  • Advising Virgin Media in the tax aspects of its US$23.3 billion acquisition by Liberty Global

Catherine Sear, Proskauer, Private Investment Funds Lawyer, Tax Legislation Attorney

Catherine Sear is a partner in the Tax Department and a member of the Private Investment Funds Group.

She focuses on the tax aspects of private investment fund structuring, including the structuring of carried interest and executive co-investment arrangements as well as tax issues relating to the establishment and operation of fund management businesses. She provides advice to fund managers on the tax aspects of private equity, venture capital, infrastructure, real estate and debt funds, including funds of funds, and has particular experience of...