Finance Act Handbook 2019

This content is unique to LexisNexis


This reproduction of the latest Finance Act incorporates section by section and schedule by schedule commentary written by a team of specialist tax writers and practitioners.

2019 Edition

The Handbook has been fully updated to include all the provisions of Finance Act 2019 with related commentary.


Lynnette Bober, ACA
Lynnette is a chartered accountant, a Chartered Tax Adviser, and a member of the Society of Trust and Estate Practitioners. Specialising in the field of personal taxation (including remittance basis issues and offshore trust planning) she advises clients on personal and trust taxation issues. She also contributes to various technical publications and journals. Lynnette is the deputy chairman of the ICAEW Tax Faculty Private Client Committee and on a number of its subcommittees and working parties.
Lynnette Bober has written the commentary for FA 2019, s 22, Sch 7.

Richard Cherrett
Richard Cherrett is a director in Deloitte’s International Markets business tax advisory group, and a fellow of the ICAEW. He advises large corporate groups on complex issues, principally the application of corporate debt and derivatives rules, and the taxation of cross-border flows.
Richard Cherrett has written the commentary for FA 2019, s 19, Sch 20.

Helen Cox
Helen Cox is a partner in the tax and private client practice at Fladgate LLP. Helen’s practice area combines advising on corporate and personal taxation. She acts for a wide range of clients, including private individuals, family offices, trustees and corporate entities. Helen has particular expertise in advising on corporate structures, joint ventures, succession planning and international tax planning. Helen is a Chartered Tax Adviser and a member of the Chartered Institute of Taxation.
Helen Cox has written the commentary for FA 2019, Sch 4.

Mike Dalton
Mike Dalton is Director and Head of Stamp Taxes at Grant Thornton UK LLP. Mike is a Chartered Accountant and Chartered Tax Adviser and an active member of the Stamp Taxes Practitioners’ Group. He is a member of Grant Thornton’s Real Estate team and provides a wide range of clients with both stamp taxes and property tax advice.
Mike Dalton, and Hugo Powell have co-authored the commentary for FA 2019, ss 42 to 50.

Bill Dodwell, LLB, LLM, CTA (Fellow), ACA
Bill Dodwell is Tax Director at the Office of Tax Simplification and a past president of the Chartered Institute of Taxation.
Bill Dodwell has written the Foreword to the handbook.

Andrew Goodall
Andrew Goodall is a freelance writer specialising in UK tax policy, law and administration. He is a regular contributor to Tax Notes, published by Tax Analysts. His work has been published by several LexisNexis UK titles including Simon's Tax Intelligence, Tolley's Tax Guide and Tax Journal. He is a non-practising member of the Chartered Institute of Taxation.
Andrew Goodall has written the commentary for FA 2019, ss 90, 92, 93.

Phil Greatrex, FCA, ATII
Phil Greatrex is a partner in CW Energy LLP. Phil has been providing tax advice to a wide range of clients in the oil and gas sector, covering petroleum revenue tax corporation tax and supplementary charge on varied, and often complex, issues for over 30 years. He has been an active member of the UKOITC and BRINDEX tax committees for many years and has extensive experience of dealing with Treasury and HMRC in lobbying for tax changes. More recently he was a member of the expert panel advising Treasury on the options available for taxation of late life assets.
Phil Greatrex has written the commentary for FA 2019, ss 37, 38, Sch 15.

Mark Groom
Mark Groom is an employment tax partner in Deloitte’s Compensation and Benefits group. He is also Vice Chairman of the Employment Taxes sub-committee of the Chartered Institute of Taxation. Mark specialises in pay and incentives, employment status and intermediaries, and benefits and expenses consulting and compliance including KYC, SAO, and HMRC investigations. He is a regular speaker at seminars and contributor to articles on employment tax matters and to HMRC consultations.
Mark Groom has advised on the commentary for FA 2019, ss 9, 10.

John Hayward
John Hayward is a former part-time self-employed pensions author. He has written for Pensions World and Tax Journal and is a member of the latter’s Editorial Board. He has contributed to Butterworth’s Tax Planning Service, Robin Ellison’s Pensions Law and Practice, Simon’s Taxes, Tolley’s Finance and Law for the Older Client, Finance Act Handbook 2004 to 2018 and the ICAEW’s TAXline. His specialist topics include small self-administered pension schemes and taxation aspects of all pension schemes.
John Hayward has written the commentary for FA 2019, s 11.

Barney Horn
Barney Horn is a senior Indirect Tax Partner with over 28 years of experience with HM Customs & Excise, Deloitte UK and Deloitte Australia. He advises businesses in a number of sectors but with a particular specialism in betting and gaming, hospitality and leisure. This advice covers a wide range of matters including VAT reclaims, dispute resolution including litigation, M&A and cross border supplies of goods and services.
Barney Horn has written the commentary for FA 2019, Sch 19.

Jo Houghton
Jo Houghton is a UK Chartered Accountant and Chartered Tax Adviser. She specialises in corporate tax and has worked both in industry and as a senior manager in practice with PwC. In addition, Jo has worked as a CPD tax lecturer with Mercia Group, a national training provider, where she lectured on a range of topic areas including business tax and tax accounting. Jo is currently a technical writer at LexisNexis.
Jo Houghton has written the commentary for FA 2019, ss 24, 83, 84, Sch 14.

Andrew Hubbard, BMus, PhD, CTA (Fellow), ATT (Fellow)
Andrew Hubbard is the editor-in-chief of Taxation magazine. He is a long-term contributor to Tolley’s Tax Planning and Finance Act Handbook. In 2006 he won the tax writer of the year award at the Taxation Awards and is a former president of both the CIOT and the ATT. He is well known as a writer and lecturer on tax matters. He has recently retired as a partner in the Nottingham office of RSM where he specialised in tax dispute resolution and the taxation of entrepreneurial businesses. Andrew originally trained as a musician before joining the Inland Revenue as an Inspector of Taxes.
Andrew Hubbard has written the commentary for FA 2019, ss 80–82, 85–87, 95.

Lydia Hutchinson
Lydia Hutchinson has been writing on corporation tax for Simon’s Taxes and TolleyGuidance since 2017. She qualified as a solicitor in 2011 having trained at Dechert, before joining the Freshfields tax team, and subsequently the tax team at Olswang (now CMS). She advised on all areas of corporate tax, as well as some aspects of tax for individuals.
Lydia Hutchinson has written the commentary for FA 2019, Sch 6.

Zigurds Kronbergs, BSc, ARCS, MA, ACA, FCCA
Zigurds Kronbergs is an experienced writer on UK, European and international tax, and is a regular contributor to several publications, including Finance Act Handbook. A specialist in tax for 40 years, he is also European Tax Coordinator for Moore Stephens Europe Ltd and the correspondent on Latvia and several UK chapters for the IBFD.
Zigurds Kronbergs has written the Introduction to FA 2019.

John Lindsay, BA, FCA, FTII
John Lindsay is a consultant in the tax department of Linklaters LLP. He advises on all corporate taxes with a focus on the taxation of capital market and securitisation transactions. John is a contributor to Simon's Taxes, Simon's Tax Planning and Tolley's Tax Planning and is also a co-author of the Taxation of Companies and Company Reconstructions (Sweet & Maxwell, 2009). He is a member of both the CIOT Technical Committee and the CIOT Corporate Tax Sub-committee and is also a member of a number of HMRC working groups.
John Lindsay has written the commentary for FA 2019, ss 28, 29, Schs 11, 12.

Lisa Macpherson
Lisa Macpherson is the Head of Tax Technical at PKF Francis Clark, supporting the firm’s teams on tax policy and technical issues across its offices and also across the wider PKF network. She has more than 20 years’ experience working in all areas of taxation including compliance and consultancy. For the last fifteen years Lisa has specialised in dealing with inheritance tax planning, onshore and offshore trust taxation, residence and domicile issues, capital gains tax and pre-owned assets tax for a number of high net worth clients.
Lisa Macpherson has written the commentary for FA 2019, Schs 1, 2.

Pete Miller, CTA (Fellow), Partner, The Miller Partnership
Pete Miller has worked in tax for 31 years, starting as an Inspector of Taxes where he had roles in Policy and Technical Divisions and was the Inland Revenue’s expert on distributions. He spent 11 years in ‘Big 4’ firms, specialising in corporate transactions, before founding The Miller Partnership, which advices other advisers on transactions in securities, reorganisations, reconstructions, distributions, partnerships, Patent Box, HMRC clearances and intangible assets. Pete speaks and writes regularly on tax and is General Editor of Whiteman and Sherry on Capital Gains Tax and on Income Tax and is on the Editorial Boards of Taxation, The Tax Journal and Simon’s Taxes.

Hugo Powell
Hugo Powell is a manager at Grant Thornton UK LLP. Hugo is a Chartered Accountant and a member of the CIOT. He sits in Grant Thornton’s Real Estate team and provides advice to a wide range of funds and property investment companies.
Hugo Powell and Mike Dalton have co-authored the commentary for FA 2019, ss 42 to 50.

Lynne Poyser, BMedSc (Hons), ATT, CTA
Lynne Poyser is the in-house writer of the Personal Tax module of TolleyGuidance. An expert in personal taxation with over 15 years’ experience, Lynne joined Tolley from BDO, where she worked in the private client team and the national tax training department, having previously worked for Grant Thornton and Arthur Andersen. Lynne has written for Taxwise 1, Taxation magazine, Tax Adviser magazine and has been a tutor for Tolley Exam Training. She is also the former Chairman of the London branch of ATT and CIOT.
Lynne Poyser has written the commentary for FA 2019, ss 1, 3–6, 11, 40.

David Rudling, CTA
David Rudling is a technical writer with LexisNexis. Before joining LexisNexis he worked for HMRC, in industry, and for a Big Four firm of accountants. He specialises in VAT and is involved in the production of De Voil Indirect Tax Service, Tolley’s VAT Planning, Tolley’s VAT Handbook and Tolley’s VAT cases.
David has written the commentary for FA 2019, ss 51–53 and Schs 17, 18.

Ben Saunders
Ben Saunders specialises in owner-managed business tax issues. He has a wide range of experience from his time in practice, training in a mixed tax role at PKF before moving to roles advising large corporate clients at PwC and then personal tax clients at UHY. During his time at PwC Ben was part of the firm’s research and development tax relief network and he went on to work as an independent adviser helping businesses claim R&D tax relief before joining Tolley. In addition to TolleyGuidance, Ben has written for Taxation magazine, Taxwise and Tolley’s Tax Digest.
Ben Saunders has written the commentary for FA 2019, ss 31–35, Sch 13.

David Smailes, FCA
David Smailes is a senior tax writer on the staff of LexisNexis and is the current author of Tolley's Income Tax. His career in tax publishing has taken in many publications, and he previously worked full-time in tax practice with medium to large professional firms.
David Smailes has written the commentary for FA 2019, ss 2, 7, 8.

James Stewart
James Stewart is a senior counsel in the tax department at Taylor Wessing LLP. He works on a range of matters including commercial real estate and finance transactions, specialising in corporation tax, stamp taxes and VAT. James is a solicitor and Chartered Tax Adviser.
James Stewart has written the commentary for FA 2019, s 17, Sch 5.

Matt Stringer
Matt Stringer is the Head of International Tax at Grant Thornton UK. He has a decade of experience in large corporate and international tax, working with both inbound and outbound multinational groups. Matt has particular expertise in cross border structuring matters and the OECD BEPS initiatives, with recent experience across Diverted Profits Tax, Anti-Hybrid rules and structuring opportunities for US multinationals in light of US tax reform measures. Matt writes for Tax Adviser magazine in the UK, with recently published articles on Diverted Profits Tax, State Aid and the new UK Digital Services Tax.
Matt Stringer has written the commentary for FA 2019, ss 15, 20, Sch 3.

Edd Thompson
Edd Thompson is a Chartered Accountant and Chartered Tax Adviser. He trained and worked in a top 10 accountancy firm for a number of years where he provided indirect tax advice to a broad range of clients including large corporates, owner managed businesses, public bodies and not-for-profits. He now works for Tolley as a technical writer where he contributes to several publications including De Voil Indirect Tax Service and De Voil Indirect Tax Intelligence.
Edd Thompson has written the commentary for FA 2019, ss 54–61.

Helen Thompson, ACA
Helen Thompson is a partner in Deloitte’s indirect tax practice, specialising in environmental taxes and VAT, and leads Deloitte’s Environmental Taxes group. She also chaired the CIOT’s Environmental Taxes Working Group from 2007–2010. Helen has extensive experience in advising businesses on their environmental tax obligations and liabilities and has provided specialist environmental due diligence services in relation to major acquisitions.
Helen Thompson and Mike Trotman have co-authored the commentary for FA 2019 ss 69–79, 91.

Mike Trotman
Mike Trotman is an associate director in Deloitte LLP with more than 25 years’ experience in indirect taxation. In Deloitte Mike has provided a firm-wide resource on environmental tax matters for over 17 years. Mike is a member of the CIOT Indirect Tax Technical Sub-Committee where he focusses on environmental taxes and has been a special advisor to the devolved governments in the UK in connection with devolution of environmental taxes from central government.
Mike Trotman and Helen Thompson have co-authored the commentary for FA 2019, ss 69–79, 91.

Kevin Walton
Kevin Walton is an in-house writer with Tolley. He is the author of Tolley’s Capital Gains Tax, Tolley’s Corporation Tax and Tolley’s Capital Allowances.
Kevin Walton has written the commentary for FA 2019, s 30.

Richard Whitaker, TEP
Richard Whitaker qualified as a solicitor in 2013 after spending 12 years in the military as a musician. Before joining Tolley, he worked in practice advising clients on Wills, trusts, estate administration and inheritance tax. Richard is a full member of the Society of Trust and Estate Practitioners (STEP) and is currently the senior examiner and a technical author for the STEP Advanced Certificate in Administration of Estates.
Richard Whitaker has written the commentary for FA 2019, s 66.