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Sanzar Partnership? New IOM company

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    Originally posted by helen7 View Post
    any change people could stick to the topic and quit the stupid one liners...

    Anyway, it seems that montpellier have responded verbally to some consulatants that there arrangement in unaffected by the changes!!!! I am waiting to see why.

    Anybody else heard from them yet?
    chance

    their

    consultants

    is

    Should we stick to English too?

    Comment


      Originally posted by helen7 View Post
      any change people could stick to the topic and quit the stupid one liners...
      No.

      Originally posted by helen7 View Post
      Anyway, it seems that montpellier have responded verbally to some consulatants that there arrangement in unaffected by the changes!!!! I am waiting to see why.

      Anybody else heard from them yet?

      Ha ha. Always trust the nice salesman. Salesmen never lie.

      Comment


        Originally posted by TheFaQQer View Post
        Is that because you were dressed as Superman and scaling the walls of Buckingham Palace at the time?
        No - I was holding a 54 foot ladder which Batman and Robin were climbing at 3:30am.

        I was a bit lippy and was roughed up. Thrown in back of van. went to talk to rest of support crew. plod came back and said "are you f4j?". me "yes". plod "I am formally de-arresting you". snarled and pointed angrily "dont tell me a porkie again".

        seems that were expecting us following night - decision already made to stop us without arresting us. they even let us take our ladder down....

        Comment


          ******.

          Anyway, back to topic. It seems to responce came from their legal department. Waiting to hear back from them myself today.

          Comment


            Originally posted by helen7 View Post
            ******.

            Anyway, back to topic. It seems to responce came from their legal department. Waiting to hear back from them myself today.
            response

            HTH
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            Comment


              They Dont Know

              Originally posted by helen7 View Post
              ******.

              Anyway, back to topic. It seems to responce came from their legal department. Waiting to hear back from them myself today.
              How can they comment when they havent seen the legislation yet?

              Comment


                changes are published on the site. Document is residence-foreign-partners.pdf


                1 UK residents and foreign partnerships
                (1) In section 115 of ICTA (partnerships involving companies: supplementary),
                after subsection (5B) insert—
                “(5C) For the purposes of subsections (5) to (5B) the members of a partnership
                include any company which is entitled to a share of income or capital
                gains of the partnership.”
                (2) In section 59 of TCGA 1992 (partnerships) insert at the end—
                “(4) For the purposes of subsections (2) and (3) the members of a
                partnership include any person entitled to a share of capital gains of the
                partnership.”
                (3) In section 858 of ITTOIA 2005 (resident partners and double taxation
                agreements) insert at the end—
                “(4) For the purposes of this section, the members of a firm include any
                person entitled to a share of income of the firm.”
                (4) The amendments made by subsections (1) to (3) are to be treated as always
                having had effect.
                (5) For the purposes of the predecessor provisions, the members of a partnership
                are to be treated as having included, at all times to which those provisions
                applied, a person entitled to a share of income or capital gains of the
                partnership.
                (6) “The predecessor provisions” means—
                (a) section 153(4) and (5) of the Income and Corporation Taxes Act 1970
                (c. 10) (as it had effect under section 62(2) of F(No. 2)A 1987), and
                (b) sections 112(4) to (6) and 115(5) of ICTA.

                1 UK residents and foreign enterprises
                (1) After section 815A of ICTA insert—
                “815AZA UK residents and foreign enterprises
                (1) Where arrangements having effect under section 788 make the
                provision mentioned in subsection (2) (however expressed), that
                provision does not prevent income of a person resident in the United
                Kingdom being chargeable to income tax or corporation tax.
                (2) The provision is that the profits of an enterprise which is resident
                outside the United Kingdom, or carries on a trade, profession or
                business the control or management of which is situated outside the
                United Kingdom, are not to be subject to United Kingdom tax except in
                so far as they are attributable to a permanent establishment of the
                enterprise in the United Kingdom.
                (3) A person is resident in the United Kingdom for the purposes of this
                section if the person is so resident for the purposes of the arrangements
                having effect under section 788.
                (4) This section does not apply in relation to—
                (a) income of a company resident in the United Kingdom to which
                section 115(5A) applies, or
                (b) income of a person resident in the United Kingdom to which
                section 858 of ITTOIA 2005 applies.”
                (2) The amendment made by subsection (1) has effect in relation to income arising
                on or after 12 March 2008.

                Comment


                  Originally posted by helen7 View Post
                  changes are published on the site. Document is residence-foreign-partners.pdf


                  1 UK residents and foreign partnerships
                  (1) In section 115 of ICTA (partnerships involving companies: supplementary),
                  after subsection (5B) insert—
                  “(5C) For the purposes of subsections (5) to (5B) the members of a partnership
                  include any company which is entitled to a share of income or capital
                  gains of the partnership.”
                  (2) In section 59 of TCGA 1992 (partnerships) insert at the end—
                  “(4) For the purposes of subsections (2) and (3) the members of a
                  partnership include any person entitled to a share of capital gains of the
                  partnership.”
                  (3) In section 858 of ITTOIA 2005 (resident partners and double taxation
                  agreements) insert at the end—
                  “(4) For the purposes of this section, the members of a firm include any
                  person entitled to a share of income of the firm.”
                  (4) The amendments made by subsections (1) to (3) are to be treated as always
                  having had effect.
                  (5) For the purposes of the predecessor provisions, the members of a partnership
                  are to be treated as having included, at all times to which those provisions
                  applied, a person entitled to a share of income or capital gains of the
                  partnership.
                  (6) “The predecessor provisions” means—
                  (a) section 153(4) and (5) of the Income and Corporation Taxes Act 1970
                  (c. 10) (as it had effect under section 62(2) of F(No. 2)A 1987), and
                  (b) sections 112(4) to (6) and 115(5) of ICTA.

                  1 UK residents and foreign enterprises
                  (1) After section 815A of ICTA insert—
                  “815AZA UK residents and foreign enterprises
                  (1) Where arrangements having effect under section 788 make the
                  provision mentioned in subsection (2) (however expressed), that
                  provision does not prevent income of a person resident in the United
                  Kingdom being chargeable to income tax or corporation tax.
                  (2) The provision is that the profits of an enterprise which is resident
                  outside the United Kingdom, or carries on a trade, profession or
                  business the control or management of which is situated outside the
                  United Kingdom, are not to be subject to United Kingdom tax except in
                  so far as they are attributable to a permanent establishment of the
                  enterprise in the United Kingdom.
                  (3) A person is resident in the United Kingdom for the purposes of this
                  section if the person is so resident for the purposes of the arrangements
                  having effect under section 788.
                  (4) This section does not apply in relation to—
                  (a) income of a company resident in the United Kingdom to which
                  section 115(5A) applies, or
                  (b) income of a person resident in the United Kingdom to which
                  section 858 of ITTOIA 2005 applies.”
                  (2) The amendment made by subsection (1) has effect in relation to income arising
                  on or after 12 March 2008.
                  Have montpelier given any idea how long it will take to respond to you?

                  Comment


                    Well most of the management team are away apparently on holiday. But since the budget also targeted a couple of other arrangements they run I am sure they will be back sharpish.

                    No indication yet as to when they will respond. Communication has never been their strong point

                    Comment


                      Originally posted by helen7 View Post
                      Well most of the management team are away apparently on holiday. But since the budget also targeted a couple of other arrangements they run I am sure they will be back sharpish.

                      No indication yet as to when they will respond. Communication has never been their strong point


                      They booked holidays for budget day, classic!!

                      Comment

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