UK Tax Guide 2014

UK advisory guide

MHA MacIntyre Hudson is a top 20 UK accounting firm offering a full range of compliance and advisory services to entrepreneurial businesses, groups and multinationals with operations in the UK. The firm has 80 partners and 500+ staff in 12 offices in London and the South East, and across East Anglia and the Midlands.

Our comprehensive range of services and specialist advice include:

• Advisory services

• Bookkeeping

• Business strategy and opportunities services

• Compliance services including business assurance and taxation

• Corporate finance

• Corporate recovery

• Counter fraud

• Employment taxes planning

• Full accountancy compliance support

• International support

• Outsourcing

• Payroll

• Proactive Tax and VAT planning (company and private)

• Professional training services, in particular to the legal and banking professions

About MHA

MHA We, along with eight other leading firms formed MHA in November 2010, a new concept for the accountancy market. Today MHA is a UK wide association of nine respected and progressive independent accountant and business adviser firms with 46 offices nationwide, all sharing common values and goals.

Each firm is characterised by its strong reputation in its region for providing accountancy and business advice to entrepreneurial businesses. By joining together as part of MHA, member firms can offer clients an increased number of specialist accountancy services and expert business advice as well as benefiting from the in-depth sector knowledge. Since we were founded, we have worked with clients in almost all industry sectors, but most have one thing in common: they are substantial businesses like us. For more information, please visit: www.macintyrehudson.co.uk

Morison International We became the UK member of Morison International, a global association of almost 100 independent accountants, auditors, tax advisers, business consultants and lawyers across 68 countries worldwide. The Morison network is active and strong providing advice on cross border matters through liaison amongst members who meet several times a year enabling them to discuss client matters with a known friend rather than a name in a directory. For more information, please visit: http://www.morisoninternational.com/

International Tax partners

Bedford: Marcel Grech Marguerat t: +44 (0)1234 268761 e: marcel.grechmarguerat@mhllp.co.uk

Canterbury: Glen Thomas t: +44 (0)1227 464991 e: glen.thomas@mhllp.co.uk

Chelmsford: Andrew Snowdon t: +44 (0)1245 353177 e:andrew.snowdon@mhllp.co.uk

High Wycombe: Patrick King t: +44 (0)1494 441226 e: patrick.king@mhllp.co.uk

Leicester: Neil Berry t: +44 (0)116 289 4289 e: neil.berry@mhllp.co.uk

London City: Alan Craddock t: +44 (0)20 7429 0531 e: alan.craddock@mhllp.co.uk

Chris Blundell t: +44 (0)20 7429 4100 e: chris.blundell@mhllp.co.uk

Gerry Myton t: +44 (0)20 7429 4100 e: gerry.myton@mhllp.co.uk

London North: Nigel May t: +44 (0)20 8446 0922 e: nigel.may@mhllp.co.uk Maidstone: Glen Thomas t: +44 (0)1622 754033 e: glen.thomas@mhllp.co.uk

Milton Keynes: Rachel Nutt t: +44 (0)1604 624011 e: rachel.nutt@mhllp.co.uk

Northampton: Rachel Nutt t: +44 (0)1604 624011 e: rachel.nutt@mhllp.co.uk

Peterborough: Kevin Edwards t: +44 (0)1733 568491 e: kevin.edwards@mhllp.co.uk

Reading: Chris Denning t: +44 (0)118 950 3895 e: chris.denning@mhllp.co.uk

International Business Howard Lewis t: +44 (0)20 7429 4100 e: howard.lewis@mhllp.co.uk Yogan A. Patel t: +44 (0)20 7429 4100 e: yogan.a.patel@mhllp.co.uk

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BackgroundIn recent years, the UK Government has put in place measures to try and make the UK the best place in the world to locate an international business.

With Corporation tax rates set to be the joint lowest in the G20 from April 2015 (20%) and competitive reliefs for innovation and high tech industries, ‘The Corporate Tax Road Map’ has set out to achieve a stable tax system providing business with confidence to expand and grow.

This report goes through some of the key aspects of the UK tax system and covers key issues associated with doing business in the UK.

Setting up companies in the UK is a relatively simple process and companies can set up banking facilities and start to trade relatively quickly whilst accessing the same support from HMRC as local firms. There is also the potential to operate via Limited Liability Partnerships (LLPs).

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Business TaxesUK Corporation Tax

A UK resident company (either Limited Company - Ltd or Public Limited Company – PLC) is liable to UK corporation tax on its worldwide income and capital gains.

The main rate (for profits over £1,500,000) of Corporation tax in the UK from 1 April 2014 is 21% and from 1 April 2015, the main rate will be 20%. Profits up to £300,000 will be taxed at 20% and there is a marginal rate applicable between £300,000 and £1,500,000. Worldwide associated companies and periods of less than 12 months will lower the profit level bands.

A non resident UK company that carries on a trade through a permanent establishment in the UK will be taxed on all income and capital gains arising in the UK that are attributable to that permanent establishment. Issues surrounding what is considered to be a permanent establishment are discussed in Appendix 1.

Companies that pay tax at the main rate for more than one accounting period (subject to exceptions) will need to pay their UK corporation tax in 4 equal instalments. For an accounting period of 12 months, the instalments will need to be paid 6 months and 14 days after the first day of the accounting period and quarterly from then. For all other companies, corporation tax is due 9 months and 1 day from the end of the accounting period.

Capital Gains

Capital gains will be taxed within the company at Corporate tax rates. For a non resident company with a permanent establishment in the UK, only assets used in the UK trade will be subject to capital gains tax.

There is an exemption - the Substantial Shareholdings Exemption (“SSE”) for investments in qualifying trading companies where the company has more than a 10% stake held for 12 months. SSE is subject to a number of conditions which need to be met for the disposal to qualify and this needs to be carefully considered.

Capital Allowances

Depreciation is not an allowable expense for tax purposes. Instead, capital allowances are available, at fixed rates depending on the type of asset.

Capital allowances are available for expenditure on qualifying plant and machinery at 18% per annum writing down allowance (WDA). Certain assets that are integral to a building will qualify for allowances at 8% WDA such as electrical systems, heating and cooling systems. The Government also introduced an Annual Investment Allowance to try and reduce the compliance burden of operating the capital allowance system on smaller businesses. Until 31 December 2015, qualifying expenditure up to £500,000 will be eligible for a 100% deduction in the year of acquisition, although from 1 January 2016, the rate will reduce to £25,000 (although these dates and rates are subject to change).

Research and Development

R&D tax relief is only available for companies – and there are two different R&D tax relief schemes depending on the size of your company.

R&D tax credits can be claimed on the cost of employing staff who are directly or actively engaged in carrying out the R&D, the cost of the materials that are used in the R&D and on payments made to certain subcontractors that are assisting with the R&D. For an SME, a business can claim relief in one of two ways. It can set 225% of its qualifying expenditure against taxable profits; that is, it can reduce the amount of the profits on which it has to pay tax by an additional 125% of the qualifying R&D spend. Or if a business makes a loss, it can take advantage of a credit by claiming 32.6p per £1 cash spent on the qualifying R&D.

For larger companies (over 500 staff), the benefits are lower. However, from April 2013, the benefit can be accounted for within operating profit (i.e. it will increase the accounting profit) rather than in the tax charge – as well as increasing the benefit to profitable companies (to 7.7%), it will make the relief more visible to the board and shareholders, and will also provide for a 7.7% cash refund for non tax paying companies.

R&D includes any project that aims to achieve an advance in science or technology through the resolution of scientific or technological uncertainties, i.e. something that is new and difficult. The definition is therefore very broad and is likely to encompass some element of the work undertaken not just by technology companies but also a number of businesses in almost every other sector. Examples of projects that would qualify

are:

• Development of a new, bespoke software system for the business (either with or without assistance from a software development firm)

• Development of a new, or appreciably improved, product

• Design and implementation of a new process

R&D claims are commonly made by businesses in the engineering, pharmaceutical, software development, manufacturing and biotechnology fields, but successful claims have also been made by some of our architect, design engineers and construction clients too.

The benefits of R&D tax relief reduce the cost of carrying out R&D in the UK but they are still very much under claimed, mainly due to a lack of awareness. It is estimated that only 20% of the businesses that could claim are actually claiming. Whilst HMRC has dramatically improved its processes to streamline R&D claims, it remains essential to obtain the support of an experienced tax adviser.

Patent Box

From April 2013 if you either own or have an exclusive licence over a patent that is registered in the UK or in certain other European countries, you can benefit from a reduced tax rate, eventually as low as 10%. Even though this rate is only applicable to profits related to these patents, the profits that qualify are very broad:

• On the sale of products, it is not just the profit on the product but also the profit from any item of which the patented product is an integral part and any consumables or bespoke spare parts for that product.

• By way of example, if there is a patent over the wing mirror of a car, the profit from the whole car will qualify (and if sold together, potentially also the profit from the maintenance contract). Similarly, if there is a patent over a roller in a printer, not only will the profit on whole printer qualify, but also the profit on the (much more lucrative) printer cartridges

• Royalties, milestones and licence fees also qualify, as do the sale of the patent and any income

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received following an infringement of your patent

• Where the patent is used in a process, or in order to provide a service, it is also possible to bring in an element of these profits

Therefore if you have a patent in your business and you are making profits, patent box will provide you with a benefit.

There are certain entry criteria that need to be met although again these are widely drawn – as well as owning the patent, an exclusive licence will also bring a company into the scheme. This is particularly useful in international structures where the IP is all held in one location – as long as the patent is from one of the approved patent offices, and there is an exclusive licence by territory (for example exclusive in the UK), the UK company’s worldwide income can qualify. Similarly even if the patent is purely, for example, German, all worldwide income will qualify.

It is also important to note that patent box will not reduce the value of your R&D tax relief (i.e. you will still get the benefit of the R&D at the full rate of tax). Therefore in many cases effective tax rates can be substantially lower than 10%

There is a specific anti avoidance condition in that the company must have developed the IP behind the patent, however even this has been extended such that the UK company can qualify as long as the development took place within the worldwide group.

Whilst the patent box calculation is very formulaic, there are some complications and it is advisable to obtain the support of an experienced tax adviser to ensure the benefits are maximised. MHA Macintyre Hudson have been involved in discussions with HMRC since the inception of this relief and are therefore ideally placed to assist.

Income and Employment TaxesIncome Tax

UK Resident persons are generally subject to income tax on their

worldwide income as it arises. Non-residents are normally only subject to income tax on income arising in the UK. Broadly, UK resident individuals will be liable to capital gains tax whilst non-residents are not. From April 2015, non residents will be liable for capital gains tax on UK residential property.

Statutory residence

The Government has introduced a statutory residence test, which took effect from April 2013. This has been designed to ensure greater certainty to all individuals, including those with more complex living and working arrangements. This looks at a range of different measures including the ‘day count’ but includes other factors such as UK accommodation, business interests and location of the wider family.

Domicile

Under UK law, an individual is domiciled, broadly, where he has his ‘permanent home’. This is not the place that he happens to be living temporarily from time to time, but the country which he regards as his real homeland. It is often described as the country in which a person plans to ultimately settle or retire. Everyone must be domiciled in one territory at any particular time throughout their life. However, the concept of domicile is distinct from nationality, residence or citizenship. It is not possible for an individual to have ‘dual domicile’ status under UK law.

If an individual is resident in the UK but is not domiciled here, income and capital gains arising abroad may be taxed on the ‘remittance basis’ (rather than the arising basis) so, the income or gains are not charged to tax unless and until they are remitted to the UK.

In most cases, a claim to be taxed on the remittance basis must be made. Where an individual has been resident in the UK for 7 out of the last 9 tax years, a ‘remittance basis charge’ (an annual tax charge) of £30,000 will also be payable to HMRC. With effect from 6 April 2012 the remittance basis charge increased to £50,000 for those who have been in the UK for 12 or more out of the previous 14 tax years.

Rates

For individuals, the tax year runs from 6 April. The following main rates and exemptions apply as of 6 April 2014:

• personal allowance of £10,000 (reducing for those with incomes exceeding £100,000)

• basic rate of 20 per cent on the first £31,865 of taxable income

• higher rate of 40 per cent on £31,865 to £150,000

• 45 per cent top rate on taxable income above £150,000

National Insurance

National Insurance contributions (NICs) are payable by employees at rates of 12 per cent on weekly income between £153 and £805 and two per cent on income above this limit. Employers also pay NICs on the earnings of their employees above £153 per week at 13.8 per cent, including benefits in kind. There is no upper cap on employers’ NICs. From April 2014, businesses and charities will be eligible for a new £2,000 Employment Allowance, which will reduce their employer NICs bill.

If an employee is to be sent to the UK for a temporary assignment then it may be possible for the worker to make social security contributions in their home territory. This will depend on the country from which the worker is being sent. To obtain such an agreement a form A1 will need to be completed and sent to the social security office in the home country.

Irrespective of whether there is a base of employment in the UK if the worker is being sent from an EEA country to the UK then the employer would have to account for National Insurance on earnings paid – this would be excused if an A1 form had been granted.

PAYEIf it is intended to either employ workers in the UK (local hires) or to bring workers to the UK then you will need to set up a UK payroll and operate PAYE and UK social security (termed National Insurance) on payments made. There, are exceptions if the workers period of assignment to the UK is for less than 183 days and HMRC have granted a short-term business visitor agreement. If the employer does not have business premises in the UK then HMRC may not require PAYE to be applied on payments made to workers but then the

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responsibility will pass to the workers to account for the tax due personally. It may however, be necessary to operate National Insurance on payments made (see above).

If the employee is seconded by their employer to work in the UK and the period of that secondment is for less than 24 months, then their base of work for tax purposes will be their previous employment base and they can claim expenses for travel and subsistence. It is important before making payments free of tax to have HMRC agreement to the detail of what is to be paid.

Capital gains tax

UK capital gains tax rates are low. The top rate is 28 per cent, with lower rates and reliefs available to support entrepreneurial and business activity. The annual exempt amount – currently £11,000 – and the exemption for main homes ensure that a large number of taxpayers do not pay CGT.

There is also Entrepreneurs Relief which reduces capital gains tax on qualifying business interests to a flat rate of 10% up to the first £10m of gains. This can include business assets, shares in a personal company (where you own more than 5% of the shares for 12 months and are a director/employee in the company) and interests in partnerships.

Share Schemes

There are a range of different incentivised UK share schemes for employees and where the conditions are met, these can be tax efficient for both employer and employee as many of them are approved by HMRC. A common restriction for these share schemes is the company must not be a subsidiary of another company. This may rule it out if there is a foreign holding company but will not be an issue if the UK company is standalone.

However, if there is a non UK holding company, it may be possible to set up an approved UK sub plan to provide significant tax benefits. Advice must be sought on this as most solutions are tailor made. Construction Industry Scheme

Carrying out ‘construction activities’ in the UK, whether done via a branch or a UK subsidiary will give rise to compliance

issues under the Construction Industry Scheme (CIS). Construction activities can include site preparation work, dismantling, alterations, construction, repairs, demolition and decoration. The scheme applies whether the construction activities are undertaken by a corporate entity such as a limited company, a partnership or a self employed individual.

Those who carry out ‘construction operations’ in the UK are required to be registered with HMRC, who will determine whether payments they are due to be paid for the labour element of their contract can be paid gross or under deduction of tax and, if the latter, the level of tax to be withheld (usually 20% of sums paid but can be as high as 30%). When deciding whether tax should be withheld, HMRC will consider the past tax compliance of the contractor and its directors/shareholders.

The CIS rules apply to construction operations which take place either on the UK mainland or within British territorial waters regardless of the tax residence status of the sub contractor. If HMRC decide that tax should be withheld on payments received then any tax paid will be used to set against tax or National Insurance due from the recipient. Any balance not required will be repaid. It is usually the case that repayment will not be made until after the contractors tax computations have been agreed by HMRC for the trading period in which the tax was withheld.

If the contractor is engaging labour on a self employed basis to undertake ‘construction operations’ then they must register with HMRC and operate the subcontractor scheme on payments they make to subcontractors. Again this applies to any construction operation taking place in mainland UK or in British territorial waters regardless of where the contractor is based. These rules require the contractor to approach HMRC before making payment to the subcontractor for the first time.

HMRC will instruct over whether the payment can be made gross or whether tax is to be deducted on the labour element of the payment. On a monthly basis, the contractor is required to make a return of payments made and to pay over to HMRC tax withheld. The monthly return requires the contractor to certify that the workers engaged were self employed (otherwise PAYE and National Insurance should have been operated -

see below).

CIS is an important issue facing non UK entities carrying out construction activities in the UK. Failure to get the compliance right will lead to the payment being made with 20% being withheld and paid over directly to HMRC. To retrieve this 20% from HMRC can be a lengthy and painful process whilst getting the basic compliance right from the beginning can ensure a smooth operation is maintained.

Specific tax rules - expenses

It is common within the UK construction industry for contractors to comply with ‘working rule agreements’ in the level of payment of expenses to workers. Working rule agreements are industry wide and are agreed on a national basis between the Trades Unions and industry representatives.HMRC will agree to expense payments, which are within the limits set out in these ‘working rule’ agreements, being paid free of income tax and National Insurance if the contractor confirms that all the rules of the ‘working rule’ agreement will be followed on site. Before payments can be made gross, however, HMRC has to give permission in the form of what is known as a PAYE dispensation.

Indirect TaxVAT

VAT is chargeable on the supply of most goods and services in the UK. The standard rate of VAT in the UK is 20% with a reduced rate of 5%. Some supplies are also zero rated and other supplies exempt completely. VAT is also charged on the import of goods from outside the EU.An entity either incorporated or unincorporated needs to be registered for VAT if their taxable turnover in any twelve months exceeds the registration threshold (2014 - £81,000). If the business expects its turnover to be over the registration threshold in the next 30 days, it will also need to register. A business can also voluntarily register if it is making taxable supplies which is under the registration threshold.The VAT position in the UK can lead to a VAT registration in the UK even though there may be no formal branch or fixed establishment in the UK.

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A UK VAT registration means that VAT will be chargeable on taxable income due under the contract. Being VAT registered means that UK VAT incurred on costs will normally be recovered in full on each VAT return submitted. VAT returns are commonly submitted quarterly where payments are due to HMRC. However, often in the construction sector building contractors may regularly receive VAT repayments as their outputs are chargeable at a reduced VAT rate of either 5% or 0%. In this situation, they can use the VAT monthly return regime to benefit from the regular VAT refunds from HMRC which helps cash-flow.

Contracts involving work on land require careful consideration about the VAT treatment and the specific details may change the place of supply for VAT purposes. ‘Land related’ supplies are treated as being made where the land is situated which can affect foreign companies who perform land related transactions (usually physical in nature) and who have no UK presence to recover the UK VAT charge on the services which they have purchased. Where contracts involve work on goods, the position is simpler and it may be possible to treat the contract as an intra-EU supply of services. This means that VAT is self-accounted for by the customer, by using the reverse charge.

Stamp Duty Land Tax

Stamp Duty Land tax is charged on the transfer of land and buildings with rates between 1% and 7%. There are special rates and rules applicable to leases.

From 1 April 2013, non natural persons may have to pay a rate of 15% on the purchase of residential properties over £2m. This limit is going down to £1m from 1 April 2015 and £0.5m from 1 April 2016.

Appendix 1

Permanent Establishment (PE)

An enterprise can be deemed to have a PE in the UK in two situations:• Where an enterprise has a fixed place of business in the UK through which the business of an enterprise is wholly or partly carried on.• Where a person, other than an agent of independent status, is acting on behalf of the enterprise in the UK and has (and habitually exercises) the authority to con-clude certain contracts that are binding on the enterprise. It should be noted that the application of these conditions may not be straight forward and each situa-tion must be carefully considered on an individual basis. However, some general points are considered below.

Fixed place of business

This definition of a PE essentially contains the following conditions, each of which must be satisfied:• The existence of a “place of busi-

ness” This is a facility such as premises, but can in certain circumstances be machin-ery or equipment. The premises do not need to be used exclusively for the pur-pose of carrying on the business of the enterprise, nor does it matter whether the premises are owned, rented or otherwise at the disposal of the enterprise, for there to be a PE.• The place of business must be

“fixed” It must be established at a distinct place with a certain degree of permanence. It is not necessary that the “fixed” place of business actually be attached to the ground upon which it stands, and cases where the presence of an enterprise is subject to minor changes in location but where there is a single commercial aim may still be considered to give rise to a PE1. With respect to what constitutes a degree of permanence, there is no strict defini-tion. This must be considered on a case by case basis and could vary considerably depending on the nature of the business. Also, the activity need not be permanent in the sense that there is no interruption of operation, but operations must be car-ried out on a regular basis.• The business of the enterprise must be wholly or partly carried on through this fixed place of business. The activity does not necessarily have to be of a productive character as the authorities take the view that within the framework of a well-run business it can be assumed that each part contributes to

the productivity of the whole. However, a number of exceptions are discussed below. The legislation2 provides that, without prejudice to the generality of the expres-sion, a “fixed place of business” includes:• A place of management;• A branch;• An office;• A factory;• A workshop,• An installation or structure for the

exploration of natural resources• A mine, an oil or gas well, a quarry

or any other place of extraction of natural resources, and

• A building site or construction or installation project, including con-struction or renovation of buildings and other structures (however under most double tax treaties, this will only apply if the project lasts more than 12 months). For this purpose, each separate site is treated as hav-ing a separate 12 month period

Notwithstanding the conditions set out above, fixed places of business that are maintained solely for the purpose of carrying on, for the enterprise, activity of a preparatory or auxiliary character are not be considered to be PEs. This would include, for example, facilities used solely for the purpose of storage, maintenance of stock, collecting information or pur-chasing. It is often difficult to distinguish between activities which have a preparatory or auxiliary character and those that do not, and each case has to be examined on its own merits. The decisive criterion is whether or not the activity of the fixed place of business in itself forms an es-sential and significant part of the activity of the enterprise as a whole.

Dependent agent

Even where an overseas enterprise does not conduct business through a fixed place of business in the UK, the fact that they are conducting business in the UK can still give rise to a PE.

An enterprise can be treated as having a PE in the UK where there is, under certain conditions, a person acting for it. The two key conditions which would both need to be met are that:

• The person must be deemed to be a dependent agent. This is essentially all agents that are not independent both legally and economically and, when acting on behalf of the enter-

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prise, are acting in the ordinary course of their own business.

Dependent agents may either be indi-viduals or companies and need not be residents of, nor have a place of busi-ness in, the UK. However, it is generally accepted that the dependent agent’s presence in the UK must be sufficient for them to be deemed to be trading in the UK, rather than with the UK. As such, if agents are present in the UK for short periods of time and on an infre-quent basis then a PE being deemed to exist is unlikely. Again, situations must be considered individually.

• The person must have the author-ity to conclude contracts in the UK that are binding on the enterprise, and must exercise this authority habitually.

This authority must be exercisable on contracts that relate to operations that constitute the actual business of the en-terprise, i.e. it would be irrelevant if the person only had the ability to conclude contracts relating to internal operations. A person who is authorised to negotiate all elements and details of a contract in a way that is binding on the over-seas enterprise shall be deemed to be exercising this authority in the UK even if the contract is ultimately signed by another person in the territory in which the overseas enterprise is situated.

Exactly what constitutes the “habitual” exercising of contracting authority is not defined and each case should be reviewed periodically. The frequency required will essentially depend on the nature of the contracts and the business of the overseas enterprise. The activities of an agent will not give rise to a PE if those activities are restricted to those that are of a prepara-tory or auxiliary character.

1 For example a market trader whose stall is not fixed to the ground and who may set up in different areas of the market on different occasions would still be considered to have a PE.

2 Paragraph 2, s1141 CTA 2010

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MHA MacIntyre Hudson is the trading name of MacIntyre Hudson LLP, a limited liability partnership, registered in England with registered number OC312313. A list of partners’ names is open for inspection at its registered office, 201 Silbury Boulevard, Milton Keynes MK9 1LZ. MacIntyre Hudson LLP is a national firm registered to carry on audit work and regulated for a range of investment business activities by the Institute of Chartered Accountants in England and Wales. It is an independent member of MHA, a national association of UK accountancy firms and a UK member of Morison International with independent member firms worldwide. Maclntyre Hudson Corporate Finance Ltd is authorised and regulated by the Financial Services Authority (FSA). Financial advice is provided in association with Carrwood Maclntyre which is an independent advisory firm and is a trading name of LighthouseCarrwood which is an appointed representative of Lighthouse Advisory Services Limited which is authorised and regulated by the Financial Services Authority. Please note that when we refer to “a partner” of MacIntyre Hudson LLP the term “partner” or “partners” indicates that the person (or persons) in question is (or are) a member(s) of MacIntyre Hudson LLP or an employee or consultant of its affiliated businesses with equivalent standing and qualifications. The word “partner” should not be construed as indicating that the members of MacIntyre Hudson LLP are carrying on a business in partnership for the purpose of the Partnership Act 1890. Partners acting as administrators or administrative receivers contract as agents and without personal liability. Further information can be found at www.macintyrehudson.co.uk/information.htm. This publication is designed for information purposes only. Whilst every effort has been made to provide accurate and up to date information, it is recommended that you consult us before taking or refraining from taking action based on matters discussed. © MHA MacIntyre Hudson. All rights reserved.