Author: Glenn

Companies developing artificial intelligence (AI) to improve safety on construction sites, reduce time spent repairing the railways and cut emissions across supply chains are amongst a number of projects set to receive a share of £32 million in UK Government funding.

Announced 7 August 2024, almost 100 ground-breaking projects have been awarded financial backing as the government continues its mission to boost productivity and kickstart growth across the economy through AI, so everyone is better off.

A total of 98 projects from Southampton to Birmingham and Northern Ireland will receive funding, involving more than 200 businesses and research organisations spanning a range of sectors including public services, driving efficiencies and reducing administrative tasks.

As part of the government’s mission to build an NHS which is fit for the future, pharmacies that deliver prescriptions across the country are also set to benefit from this new financial support. A project led by Nottingham-based Anteam will see them collaborating with retailers and the NHS to improve the efficiency of their deliveries using AI algorithms. This technology will match the delivery needs of retailers and hospitals to existing delivery journeys, unlocking under-utilised capacity, cutting carbon emissions and delivering a better experience for patients.

It was announced as part of the Spring Budget measures that the present favourable tax benefits presently allowed for the letting of properties as short-term holiday lets – known as the furnished holiday lettings (FHL) tax regime – is to be abolished from April 2025. The Labour government has confirmed that these changes will take effect as planned.

HMRC has now published a policy paper providing further details of how these changes will work in practice.

The policy paper states that the changes will remove the tax advantages that current furnished holiday let landlords have received over other property businesses in four key areas by:

• applying the finance cost restriction rules so that loan interest will be restricted to basic rate for Income Tax;
• removing capital allowances rules for new expenditure and allowing replacement of domestic items relief;
• withdrawing access to reliefs from taxes on chargeable gains for trading business assets; and
• no longer including this income within relevant UK earnings when calculating maximum pension relief.

After repeal, former FHL properties will form part of the person’s UK or overseas property business and be subject to the same rules as non-furnished holiday let property businesses.

There is also an anti-forestalling rule that prevents the obtaining of a tax advantage through the use of unconditional contracts to obtain capital gains relief under the current FHL rules. This rule applies from 6 March 2024.

The loss of the special tax regime for holiday lets is expected to have a significant effect on many of those involved with the short-term holiday rental business in the UK.

More details have been published regarding Chancellor Rachel Reeves' plans to impose a VAT charge on private school fees. The government has said that the money raised by ending the tax breaks on VAT, and business rates for private schools, will help secure additional funding for state education programs.

From 1 January 2025, all education services and vocational training supplied by a private school, or a connected person, for a charge will be subject to VAT at the standard rate of 20%. Boarding services provided by a private school, or a connected person, will also be subject to VAT at 20%. In addition, any fees paid from 29 July 2024 pertaining to the term starting in January 2025 onwards will be subject to VAT. Boarding and lodging closely related to such supplies will also be subject to 20% VAT.

The government have also said they will legislate to remove eligibility of private schools in England to business rates charitable rates relief. However, the government accepts that some students with special educational needs may require the specific support available only in private schools. As a result, the government will review how to mitigate the potential effects of these changes for students whose private school placement is outlined in an Education, Health, and Care Plan (EHCP).

Schools that do not currently make any taxable supplies, such as renting out their facilities, will be able to register with HMRC starting from 30 October 2024, the date of the Autumn Budget. Schools that already make taxable supplies can choose to register for VAT before 30 October if they so wish.

School fees that were paid before 29 July 2024 will follow the VAT treatment in force at the time of the normal tax point for these supplies, where the fee rate for the relevant term has been set and was known at the time of payment.

Goodwill is a concept frequently discussed, and yet it is seldom addressed in legislation. Typically, it is defined as the additional value of a business beyond its tangible assets.

In the vast majority of cases, when a business is sold, a significant proportion of the sale price will be for intangible assets including goodwill. Essentially, this involves assigning a monetary value to the business’s reputation and customer relationships. Or as HMRC say in their guidance, in accounting terms, purchased goodwill is the balancing figure between the purchase price of a business and the net value of the assets acquired. Valuing goodwill is complex and there are many different methods which can be used and that vary from industry to industry.

Businesses may qualify for Corporation Tax relief on purchases of goodwill made on or after 1 April 2019 if the:

• goodwill and relevant assets are purchased when you buy a business with qualifying intellectual property (IP);
• business is liable to Corporation Tax; and
• relevant assets (including goodwill) are included in the company accounts.

If relief is available, it is at a fixed rate of 6.5% a year on the lower of the cost of the relevant asset or 6 times the cost of any qualifying IP assets in the business purchased. Relief is given yearly until the limit is reached and a claim is made using the Company Tax Return.

A higher rate of CGT applies to gains on the disposal of residential property (apart from a principal private residence). In the Spring Budget 2024, the Chancellor announced a reduction in the higher rate that exists for residential property to 24% (from 28%) from 6 April 2024. These rates apply to higher rate taxpayers as well as to trustees and personal representatives. The lower rate that applies to basic rate taxpayers remain unchanged at 18% in the current 2024-25 tax year.

Most people are aware that they do not usually have to pay CGT when they sell their qualifying residential property used wholly as a main family residence. However other sales of property that are not a principle private residence (PPR) will be subject to CGT.

This includes:

• buy-to-let properties
• business premises
• land
• inherited property

The deadline for paying any CGT due on the sale of a residential property is 60 days. This means that a CGT return needs to be completed and a payment on account of any CGT due should be made within 60 days of the completion of the transaction. This applies to UK residents selling UK residential property where CGT is due. There are various reliefs available from CGT for the sale of qualifying business assets.