Our detailed analysis of the impact the budget changes are likely to have on private clients and what their advisers should be thinking about is set out below.
NON-DOM CHANGES
The key changes, which will apply from April 2017, are as follows:
Long term residents will be deemed domiciled for all tax purposes if they have been resident in the UK for 15 years in a 20 year period.
Individuals born in the UK with a UK domicile of origin will always be treated as domiciled in the UK for all tax purposes whenever they are resident in the UK. For these individuals, excluded property trusts will lose their excluded property status.
Anybody who has been in the UK for more than 15 years will be deemed to be domiciled in the UK for at least five years after they leave.
The income/capital gains tax treatment of offshore trusts set up whilst non-domiciled by individuals who have become deemed domiciled will have some new features which do not at the moment apply to non-domiciliaries who become actually domiciled in the UK.
All UK residential property held indirectly by non-domiciliaries or excluded property trusts through opaque vehicles such as companies, foundations or partnerships will be subject to inheritance tax. The rules will apply to non-residents as well as UK residents.
We have prepared a detailed note on the non-domiciled changes and a note on the current state of play for foreigners owning UK residential property. Please contact us if youwould like to receive copies of these.
INHERITANCE TAX RELIEF ON HOMES
There will be an increase in the inheritance tax nil rate band intended to enable individuals to pass their main residence on to their descendants on death without a tax charge.
The “main residence nil rate band” will take effect from 6 April 2017 at £100,000. The band will increase by £25,000 per year stopping at £175,000 in 2020/21. From 2021/22 onwards the band will increase in line with CPI.
Like the existing nil rate band (which will remain at £325,000 until 2020/21) this additional relief will be transferable between spouses/civil partners. This means that, for example, a husband and wife can combine their nil rate bands and pass a family home of up to £1m down to their children tax free. The additional relief will be transferable where the second spouse dies on or after 6 April 2017 irrespective of when the first spouse died.
The relief is restricted to property that has been the residence of the deceased at some point so it would not apply to buy-to-let property, although it could apply to a property which used to be a residence of the deceased but which was let at the date of death. In the event that there are two potentially qualifying properties, the personal representatives of the deceased can elect which one the additional nil rate band will attach to. This suggests that the property to which the additional nil rate band applies does not have to be the deceased’s “main residence” either in fact or pursuant to a principal private residence election for capital gains tax purposes.
As mentioned above, the additional nil rate band will only apply to one property and any unused element cannot be carried across to another property. This is a point the personal representatives should bear in mind when deciding which property to choose.
Where the main residence nil rate band or part of it would be lost because the deceased downsized to a less valuable property or ceased to own a property before their death, relief will still be available provided that the smaller replacement property and/or assets of equivalent value to the property which has been disposed of are passed to the deceased’s descendants. The detail of how this will work will be the subject of consultation.
This measure raises several questions including how long before their death the deceased must have downsized or ceased to own residential property. There will be a consultation on this in the autumn. Bearing in mind the policy objective is to make it easier for families to pass on the family home, we should expect this carve out to the general rule to be tightly framed.
The relief will not be available to everyone as it will be reduced for estates worth more than £2m at a withdrawal rate of £1 for every £2 over the threshold. The £2m figure is a net value after deducting liabilities but before applying any relief or exemptions (including the current nil rate band, business property relief or the spouse exemption).
PRIVATE CLIENT
OVERVIEW
SUMMER BUDGET 2015
However, there are some grandfathering provisions which mean that the new rule will not apply to assets added to more than one trust under wills executed before 10 December 2014 as long as the death (and therefore the transfer of assets into the trusts) occurs before 6 April 2017.
So that settlors can still make minor changes to their wills after 10 December 2014 without falling outside the scope of these protective provisions as a result, amendments are permitted as long as the provisions of the will on death are “in substance the same as they were immediately before 10 December 2014”. An obvious example of an amendment that would not change the substance of a will is a change of executors. Careful thought will need to be given to this point if more significant changes are proposed.
COMPANIES – CORPORATION TAX AND DIVIDEND TAX
The Chancellor announced that the main rate of corporation tax (currently set at 20 per cent - an historic low) will reduce to 19 per cent from 1 April 2017 and then to 18 per cent from 1 April 2020.
He also announced a significant change to the way in which dividends are taxed. At present, dividends attract a tax credit of 10 per cent and are then taxed at rates of 10 per cent, 32.5 per cent or 37.5 per cent for basic, higher and additional rate taxpayers respectively. This means that basic rate taxpayers presently have no tax exposure on dividends (as their liability is franked by the tax credit); higher rate taxpayers pay an effective rate of 25 per cent; and additional rate taxpayers pay an effective rate of 30.56 per cent.
From April 2016 the tax credit will be abolished and a new system imposed. There will be a new annual Dividend Tax Allowance of £5,000 (which the commentary states will be available to all taxpayers). Dividends received within this amount will not attract additional tax. Above this amount, dividends will be taxed at a rate of 7 per cent for basic rate taxpayers. The rates are then 32.5 per cent for higher rate taxpayers and 38.1 per cent for additional rate taxpayers.
This means that any taxpayer with less than £5,000 of dividend income in a tax year (so assuming an average dividend yield, around £140,000 of shares) will pay less tax than at present. Conversely, basic rate taxpayers with more than £5,000 of dividends and higher/additional rate taxpayers with more than £22,000 of dividends will pay more.
The tapering will mean that no relief is available for estates with a net value of £2.35m or more (or possibly £2.7m on the death of a surviving spouse where the full main residence nil rate band is available to be transferred to the survivor). It is this value cap rather than the provisions relating to the property set out above that really restricts the availability of the relief.
One important aspect which is not clear is whether it will be acceptable for the main residence to pass to a trust for the benefit of descendants rather than passing to them outright. In summary, although the main residence nil rate band appears to generously increase the current relief in the context of the family home, the fact that it will not be available to higher value estates, means it that in practice its scope may be limited. Where the relief is potentially available, clients should review their wills and spouses should consider the relative values of each of their estates to ensure that the maximum relief will be available.
INHERITANCE TAX NIL RATE BAND – USE OF MULTIPLE TRUSTS
The Chancellor did not discuss inheritance tax and trusts in his Summer Budget but the measures announced in his Autumn Statement in December 2014 and which have since been the subject of consultation will be introduced in the Summer Finance Bill.
The key measure is a targeted anti-avoidance rule to restrict taxpayers’ ability to reduce the amount of inheritance tax on relevant property trusts by the creation of multiple trusts. Under the new rules, the value of assets added to multiple trusts on the same day will be added together (along with assets already comprised in the trusts) for the purposes of calculating inheritance tax charges on each trust. There is a carve out for additions of £5,000 or less and additions to non-relevant property trusts are ignored.
The measure is aimed at stopping people creating separate trusts (known as pilot trusts) on different days during their life time and later funding them with substantial assets on the same day (often on the death of the settlor under the provisions of their will). Under current legislation the trusts are not related and each trust is entitled to its own inheritance tax nil rate band. The new “same day additions” rule will apply to all charges arising after the date of Royal Assent in respect of settlements created after 10 December 2014. It will also apply to trusts created before 10 December 2014 but where same day additions are made after that date.
TAX RELIEFS FOR INVESTORS IN RESIDENTIAL PROPERTY
Restricting relief for finance costs for landlords who are individuals
Following pre-Budget rumours of such a change, the Chancellor announced yesterday a restriction to the finance cost relief that landlords can currently claim, to alleviate the perceived unfair advantage that buy-to-let investors have over owner-occupiers. The Government are also seeking to address the threat identified in the Bank of England’s recent Financial Stability Report that the rapid growth of buy to let mortgages could pose a risk to the UK’s financial stability.
The current position is that individual landlords can deduct all of their finance costs (mortgage interest, interest on loans to buy furnishings and fees incurred when taking out or repaying mortgages or loans) from their rental income received to determine taxable profits on their rental investments. This means that relief is effectively given at an individual’s marginal rate of income tax (20 per cent, 40 per cent or 45 per cent). Individuals (including partnerships) who receive rental income on residential property either in the UK or abroad and who are higher or additional rate tax payers will have their ability to claim relief for finance costs gradually reduced from 6 April 2017. It is not yet clear whether trustees will be affected by the new rules but it seems likely that they will. Landlords who are basic rate taxpayers will be unaffected by the changes. Once the restrictions are fully in force from the 2020/21 tax year, this change is expected to raise an additional £665million for the Treasury. The Government calculates that 20 per cent of landlords will pay more tax as a result of this restriction. The legislation is expected to be included in the Finance (no. 2) Bill on 15 July 2015 and will not be subject to consultation. From 6 April 2017, individual landlords will be able to obtain relief as follows. In 2017-18 the deduction from property income for higher rate purposes will be restricted to 75 per cent of finance costs, with the remaining 25 per cent being available as a basic rate (i.e. 20 per cent) tax reduction. In 2018-19, the deduction for higher rate purposes will be 50 per cent of finance costs, in 2019-20, 25 per cent and from 2020-21 all financing costs incurred by a landlord will be given only as a basic rate tax reduction. If the finance costs exceed the net rental income after other deductions, any excess may be carried forward to following years.
By way of example, Jim owns a buy-to-let property worth £500,000. He has an interest only mortgage of £200,000 secured on the property at a long term fixed interest rate of 4 It is not clear how the new regime will apply to trusts. At present,
where shares are held on life interest trusts (so that any dividends belong to the life tenant) the income is taxed on the life tenant – as if he were the owner of the shares. For discretionary trusts, the trustees pay tax at the rate applicable to trusts – which for dividends is equivalent to the additional rate of 37.5 per cent (with the benefit of the 10 per cent tax credit). Although beneficiaries obtain credit for the tax paid by the trustees when the income is distributed, for technical reasons the benefit of the 10 per cent tax credit doesn’t feed through to them.
We will need to wait to see whether the £5,000 Dividend Tax Allowance applies to trustees of discretionary trusts, and indeed whether the opportunity is taken to ensure that the benefit of this is passed on to beneficiaries.
Although the reduction in corporation tax rates will be welcome news, the changes to dividend taxation will mean a material hike in effective tax rates for those with significant dividend income (with the rate of tax being increased by somewhere between 7-7.5 percentage points across the board).
The Budget materials acknowledge this; and some of the additional commentary points to a wish to discourage moves towards remuneration through dividends rather than salary. However, there will still be an advantage to taking dividends under the new regime. At present, profits paid as salary attract an effective rate of 53.43 per cent (inclusive of national insurance contributions) – which is set to remain unchanged. Profits extracted as dividend to an additional rate taxpayer attract an effective rate of 44.44 per cent. From 2016/17 this effective rate will rise to 50.48 per cent; but there will remain around a 3 per cent advantage to taking a dividend (rising to around 4 per cent by the time the 18 per cent corporation tax rate is introduced in 2020).
It is also worth bearing in mind the effect of these changes to family investment companies. The historically low corporation tax rates (offering a roll-up of profits at a 20 per cent tax cost) has made these increasingly attractive and the further rate reduction only accentuates this. Although the new dividend regime will make the payment of significant dividends more expensive in tax terms, for vehicles funded by substantial shareholder debt this will still offer a means of extracting funds in a tax efficient manner.
The reduced corporation tax rates together with the changes to interest relief may also make buy to let landlords more likely to choose to carry on their letting business through a company (see further below).
SDLT rates on purchase can be higher for corporate buyers and landlords will need to take a view on the Government’s stated desire to discourage corporate ownership of residential property in general and whether further measures will be introduced in future Budgets to make corporate ownership of buy to let properties less attractive.
Corporate landlords may face higher interest rates than individuals and certain lenders may be unwilling to accommodate existing landlords seeking to transfer their properties into a corporate structure.
The announcement of the changes to the dividend tax rate and the new dividend allowance detailed above will necessitate detailed calculations to enable a comparison between the returns available through personal ownership versus a company.
Wear and Tear allowance changes
Currently landlords with furnished properties are able to claim a flat rate 10 per cent deduction to calculate taxable profit. This generous relief is available every year, regardless of whether any expenditure is actually incurred. From 6 April 2016 this allowance will be abolished and replaced with a new relief that allows residential landlords to deduct only the actual costs of replacing furnishings when calculating their taxable profits. Few details were released on this yesterday, but the Government will publish a technical consultation before the summer. Again landlords of furnished holiday lets benefit, as the Government have confirmed that capital allowances will continue to apply to these properties.
Rent-a-room relief
There was good news for landlords who let a room in their only or main residential property. For many years the amount which can be received tax-free from a lodger has been fixed at £4,250 per year. This figure will rise to £7,500 from 6 April 2016, reducing the amount of income tax paid by many landlords in this category.
PENSIONS
Reduced pension saving limits
In order to pay for the increase to the inheritance tax nil rate band for non-residences (see above), high earners will get less tax relief for pension contributions.
Individuals can currently get tax relief on pension contributions of up to £40,000 a year. From April 2016, this will be reduced for individuals whose total income (including pension contributions) is more than £150,000 or whose total income (excluding pension contributions) is more than £110,000. per cent (i.e. his finance costs are £8,000 per annum). Jim is
a higher rate tax payer. He receives £18,000 in rent each year and has other rental expenses of £3,000 each year. All other things being equal, in 2016/17 Jim will pay £2,800 in tax on his rental income. In 2018/19 he will pay £3,600 in tax and in 2020/21 he will pay £4,400 in tax.
What can landlords do?
In terms of market stability, the phased introduction of the reduction in relief is to be welcomed, as it seems unlikely to trigger a mass exodus of landlords prior to 2017. The impact of the change will also be alleviated in the short term by the very low interest rates available at present.
The proposals will not impact on landlords with residential properties which meet all the criteria to be a furnished holiday letting and landlords looking to enter the market for the first time or to expand their portfolio may now be tempted to give careful consideration to this market with a consequential rise in the value of holiday properties.
Corporate landlords are also currently unaffected by the changes and with the announcement yesterday of a further reduction in corporation tax to 19 per cent in 2017 and 18 per cent by 2020, individual landlords may (subject to stamp duty land tax considerations) be tempted to consider transferring personally held rental properties into a company or to purchase new properties through a company.
One benefit of this would be the ability to deduct all finance costs before calculating taxable profits. Corporation tax rates are now very attractive as against income tax rates. The benefit of being able to repay acquisition loans out of rental income which has only been taxed at 18 per cent-20 per cent rather than 45 per cent is considerable. Profits could be kept in the company with no need to incur the costs of extraction until they were needed.
However, this is a complex decision requiring detailed advice, which will differ for each portfolio and each landlord’s personal circumstances. Where properties are standing at a gain, there could be an immediate charge to capital gains tax when the properties were transferred. One would need to factor in the impact of the annual tax on enveloped dwellings (ATED) charge for properties worth over £500,000. Although let properties are currently exempt from ATED, there is no guarantee that this will be the case in the future.
The change which will apply from April 2016 is that, if the lump sum is paid to an individual, the lump sum will also be taxed at the beneficiary’s own rate of tax – which may of course be less than 45 per cent.
If the lump sum is paid to a trust or to a company, it will still be taxed at 45 per cent.
Most pension funds are free of inheritance tax on death and so can be an extremely tax efficient way of passing funds on to the next generation but with any surviving spouse still being able to benefit from the funds.
In the past, the advice has often been to take funds out of a pension as quickly as possible prior to the member’s death in order to avoid the tax charges which previously applied on death. For somebody who died under 75, it would be common to provide for the lump sum death benefit to be paid to a discretionary trust.
This should all be reconsidered in the light of the current rules. The ability to roll-up funds tax free within the pension coupled with the ability for the member’s beneficiaries to take money out by way of income draw down over a period of time either tax free if the member has died under 75 or at the beneficiary’s own tax rates if the member has died over 75 and without the additional tax charges which previously applied on the member’s death, may well mean that it is now better to leave as much in the pension pot as possible for as long as possible.
A separate discretionary trust to hold the lump sum death benefit will create additional tax charges. However, this may make sense where the member does not want his beneficiaries to have unfettered access to the funds or to be exposed to claims against the beneficiary, for example, on bankruptcy or divorce.
Another benefit of transferring the pension fund to a separate discretionary trust is that the trust can then make loans to the beneficiaries. These loans will be deductible from the beneficiary’s estate for inheritance tax purposes. This may be sensible planning, for example, where there is an elderly surviving spouse in order to reduce the inheritance tax bill on the death of the surviving spouse.
Those who have not already done so, should review their pension strategy in the light of these changes and, in particular, what should happen to any death benefits.
The £40,000 eligible for relief is reduced by £1 for every £2 of income over the limits mentioned above. Everybody will get tax relief on pension contributions up to £10,000 per annum however much their income is and so this minimum relief cuts in where individuals have income (including pension contributions of over £210,000 or income (excluding pension contributions) of over £170,000).
In addition to this, the pension lifetime allowance is being reduced from £1.25m to £1m but will in future be increased each year by inflation. If the value of an individual’s pension savings exceeds the lifetime allowance, an additional tax charge of either 55 per cent or 25 per cent is payable when benefits are taken.
There is some good news for the current tax year as the normal £40,000 annual allowance is being increased to £80,000. This means that it should be possible to make further contributions before 6 April 2016. Unused allowances from the previous three years can be brought forward and continue to be used in the normal way.
Despite this, the effect of the changes is that higher earners will need to consider other ways of saving for retirement, perhaps using other tax efficient investments or investment vehicles. In this context, it is worth considering setting up a family investment company to take advantage of even lower
corporation tax rates (see above) to accumulate investments in a lower tax environment with a view to taking benefits out of the company following retirement.
Pension death benefits
Significant changes were made earlier this year to the tax treatment of pension death benefits and the options available following the death of a pension scheme member.
If the member dies under 75, the entire fund can be paid out tax free (subject to the lifetime allowance mentioned above). Alternatively, the member’s heirs can elect to draw down the funds over a period of time, effectively as tax free income. A decision however has to be made within two years of the member’s death in order to get tax free treatment.
On the other hand, if the member dies aged 75 or over, there is tax to pay. If a lump sum is taken, a flat tax rate of 45 per cent is payable. If the heirs elect for income draw down, they pay tax on the income at their own rates.
with the burden of navigating the requirements of the Common Reporting Standard will be subject to additional obligations to tell their clients about the Common Reporting Standard, the opportunities for clients to correct their affairs before its implementation (see below) and the penalties which attach to non-compliance.
The Summer Budget will provide the Treasury with the power to make regulations imposing a requirement to notify clients of their disclosure obligations. HMRC will consult with financial institutions and tax advisers as to the form of these regulations and, in particular, to develop targeted and more cost-effective (i.e. presumably, standard form) communications for clients. The regulations are expected to have effect from early 2016.
Greater HMRC scrutiny
HMRC are likely to use the information received in a more sophisticated way. Funding is being provided to HMRC to fund an expansion of HMRC’s customer relationship manager approach to apply to individuals with net wealth between £10-20m. This will mean that each taxpayer in that category will have a designated individual at HMRC assigned to them to manage their relationship with HMRC and to scrutinise their affairs. Wealthy individuals should therefore expect more correspondence with HMRC and considerably more interest in their affairs.
Additional funding will also be used to ensure that HMRC can be more active in investigating and prosecuting non-compliant taxpayers. A specialist resource within HMRC is also to be created to focus on non-compliance by trusts, pension schemes and non-domiciled individuals.
Tougher stance on non-compliant taxpayers
A tougher approach by HMRC is on the cards. The Summer Budget announces funding aimed at tripling the number of criminal investigations that HMRC can undertake into complex tax crime with a specific focus on wealthy individuals and companies.
Existing routes for resolving historical issues in taxpayer’s affairs, the Liechtenstein Disclosure Facility and the Crown Dependencies Disclosure Facility, are being brought to an end this year.
From early 2016 a new time-limited disclosure facility is likely to be the only route open to non-compliant taxpayers and is therefore billed as a “last chance” for such individuals to correct their tax affairs before information is shared under the Common Reporting Standard. Disclosure through this facility will attract
CARRIED INTERESTS FOR FUND MANAGERS
The world has changed for fund managers who receive carried interest and managers who are UK resident but non-UK domiciled will be particularly affected.
With effect from 8 July 2015 recipients of carried interest will be subject (as a minimum) to capital gains tax (28 per cent) on the full amount of that carried interest with (normally) no base cost. Before these changes many UK resident non-UK domiciled carried interest holders only pay UK tax on their carried interest if the proceeds are remitted to the UK. However, the new rules treat the gain as being UK source to the extent that the holder performs his or her investment management duties in the UK. Accordingly, UK resident non-UK domiciled individuals who perform their duties in the UK will be subject to capital gains tax on their carried interest irrespective of whether it is remitted. It is not clear how the new rules will impact on carried interest held through non-UK resident trusts. The existing UK tax anti-avoidance rules are not straight forward and the interaction between them and these new rules is likely to give rise to further complexity.
This change will have a drastic impact on funds and their principals and in many cases will result in a significantly higher tax liability. Further details on the changes to the carried interest rules can be found here.
TAX AVOIDANCE – NO PLACE TO HIDE?
The Government has continued to focus on tackling tax
avoidance as a way of generating further revenue. The Summer Budget introduces a series of new measures to support this aim and commits significant resource to HMRC to ensure they are better equipped to deal with non-compliant taxpayers.
Disclosure
The push for greater disclosure to HMRC continues. Under the Common Reporting Standard in 2017 HMRC will begin to receive a wide range of information about offshore accounts and will at the same time share information with other tax authorities. In addition to this already extensive reporting the Summer Budget announced a consultation on enhancing the information reported to HMRC by wealthy individuals and trustees.
The Summer Budget has emphasised that financial
intermediaries (including tax advisers and other professionals) will be required to take a more active role in the application of the Common Reporting Standard. Institutions already faced
CRIMINAL OFFENCE
It is clear that HMRC will pursue strong penalties in relation to offshore irregularities. The new criminal offence for failing to declare offshore income and gains which was announced earlier this year is referenced in some of the Summer Budget publications. This criminal offence has caused considerable concern as the suggestion is that it may be a strict liability offence (meaning that there does not need to be any intention to evade tax to be liable) and that there will be penalties for professionals who assist taxpayers who (even inadvertently or as a result of an interpretation of the law which turns out to be incorrect) do not declare their offshore income and gains. It is understood that a further consultation will be launched in respect of this and other sanctions next week with a view to implementation in 2016.
CONCLUSION
It is clear from dealing with HMRC that they are increasingly taking a tougher stance in their approach to taxpayers and with these new resources and powers this is a trend which is certain to continue. Wealthy individuals and trustees should, in conjunction with their advisers, expect and prepare for far greater, more informed and more regular scrutiny of their affairs. Taxpayers should now be taking steps to ensure that their affairs stand up to this scrutiny.
All of this is likely to affect both the behaviour of taxpayers and their advisers. The availability of information, coupled with high penalties and possible criminal prosecution will make people much more cautious. Aggressive tax planning is likely to become relatively rare or, at least, will only be carried out on the basis that it is fully disclosed.
penalties of at least 30 per cent on top of the tax owed (plus any interest), with no guarantee of immunity from criminal prosecution. It is therefore considerably less generous than the previous regimes.
Anybody who may have irregularities in their past tax affairs (or those of trusts with which they are connected) should urgently seek advice on whether to make disclosure under one of the existing disclosure facilities before the end of this year – time is running out.
The Summer Budget confirmed that the previously announced legislation allowing HMRC to recover tax directly from the bank accounts of non-compliant taxpayers (including funds held in ISAs) will be introduced. There has been a consultation on these powers and it is noted that safeguards will be introduced requiring HMRC to meet with the taxpayer before using these powers and allowing a county court appeal process.
General Anti-Abuse Rule
The Government will launch a consultation process in respect of new penalties for breach of the General Anti-Abuse Rule which is aimed at targeting artificial tax avoidance schemes. The new penalties will focus on tax arrangements which are deemed abusive and applies to income tax, capital gains tax, corporation tax and inheritance tax amongst others. The consultation will also consider new measures to further strengthen the General Anti-Abuse Rule.
The indication is that the penalties will be proportionate to the amount of tax recovered and taxpayers who repeatedly use tax avoidance schemes caught by the General Anti-Abuse Rule will be “named and shamed”.
It is suggested that further sanctions against such taxpayers may include restricting access to reliefs for those who have a record of trying to abuse them. Promoters of tax avoidance schemes which are regularly defeated will also be brought within the recently created Promoters of Tax Avoidance Schemes regime which allows HMRC to issue conduct notices to those promoters with the aim of improving their behaviour and subjecting them to monitoring and certain disclosure obligations if their behaviour does not improve.
CONTACT DETAILS
If you have any questions please get in touch with your normal contact or with:
JONATHAN CONDER NICHOLAS HARRIES
PARTNER PARTNER PRIVATE CLIENT PRIVATE CLIENT DD: +44 (0)20 7849 2253 DD: +44 (0)20 7849 2576 [email protected] [email protected] ROBIN VOS CONSULTANT PRIVATE CLIENT DD: +44 (0)20 7849 2393 [email protected] JULY 2015
MACFARLANES LLP 20 CURSITOR STREET LONDON EC4A 1LT
T: +44 (0)20 7831 9222 F: +44 (0)20 7831 9607 DX 138 Chancery Lane www.macfarlanes.com This note is intended to provide general information about some recent and anticipated developments which may be of interest.
It is not intended to be comprehensive nor to provide any specific legal advice and should not be acted or relied upon as doing so. Professional advice appropriate to the specific situation should always be obtained. Macfarlanes LLP is a limited liability partnership registered in England with number OC334406. Its registered office and principal place of business are at 20 Cursitor Street, London EC4A 1LT.
