1. business and industrial

Business
Update
November 2014
In this issue
Recent changes to employment taxes
We outline some of the recent changes
to employment taxes that you should be
aware of – page 2
Action on profit shifting
Proposals to target multinationals that
shift profits to low tax jurisdictions may
increase the compliance burden – page 4
Our survey of entrepreneurs
We look at the results of our survey of
UK entrepreneurs: how confident are
they about the coming year? – page 6
Business Update
Editor’s comment
Welcome to the November issue of Business Update, our regular newsletter for
business owners, company directors and their professional advisers.
We begin this issue with a round-up of some of the recent consultations that HMRC
has undertaken which might affect readers of Business Update. Our second article
looks more closely at one of these consultations in particular, as well as other
developments covering employment taxes.
Tax planning by multinational companies has become more sophisticated over recent
years and there are recommendations for reforms to international tax law to crack
down on international profit shifting. We outline the recommendations and warn such
organisations of the additional compliance burden this will bring.
Earlier this year we surveyed UK entrepreneurs, to sample their views on the UK as a
place to do business and their levels of confidence. We summarise some of the results
here.
It’s now easier to transfer ownership of a business to its employees, via a new
Employee Ownership Trust. We look at how this would work in practice.
Our final article considers amendments to FRS 102 in relation to debt and other
financing arrangements. The classification of certain debt products has now changed
to ‘basic’; we look at what this means in practice.
I hope you find this issue interesting and informative. Please do contact me or your
usual Saffery Champness partner if you would like more information on any of the
topics featured here.
John Shuffrey
A round-up of recent HMRC
consultations Page 1
Recent changes to employment taxes
Page 2
International action on profit
shifting Page 4
Our survey of UK entrepreneurs
Page 6
Employee ownership: new opportunities
for succession planning Page 7
Amendments to FRS 102 are a step in the
right direction Page 8
November 2014
A round-up of recent HMRC
consultations
Where legislative changes to the tax system are proposed, the government has
committed to consult formally with individuals, practitioners and businesses.
The aim is to ensure that any changes are well targeted and the likely impacts
understood.
We are seeing an increasing number of
consultations being published by HM
Revenue & Customs (HMRC), and in this
article we highlight some of the recent
consultations affecting businesses and their
employees.
Benefits and expenses
Following a review of employee benefits and
expenses by the Office of Tax Simplification
(OTS), four key areas of simplification are
being considered by the government.
These proposals are expected to reduce the
compliance burden for employers when it
comes to reporting expenses and benefits.
Our article on page 2 outlines the proposed
changes.
Introducing the concept of a
‘marketable security’
Following a review of the rules relating
to employee share schemes, the OTS has
recommended that individuals would be
able to choose whether a tax charge arises
at the time the securities are acquired or, if
different, when they become marketable (ie
when they can be sold for cash).
Employment-related securities
and internationally mobile
employees
Another change proposed by the OTS
concerns the taxation of share plans held by
internationally mobile employees (IMEs). The
OTS recommended that the tax and National
Insurance treatment of shares awarded to
IMEs should be more closely aligned with
that of other forms of employment income,
subject to the provisions of international
social security agreements.
Currently, where income arises on a
‘chargeable event’, such as the exercise
of options, the income is apportioned
into periods of UK residence and non-UK
residence for tax purposes, so that only
the income attributable to periods of UK
residence is charged to tax. For National
Insurance contributions (NICs) purposes,
however, the entire income is assessed to
NICs, with no apportionment for periods of
non-residence.
The consultation proposes to align the NIC
treatment with the tax treatment, so that
apportionment is possible to disregard the
days the individual was not within the UK
National Insurance system (either because
they were not resident in the UK for NIC
purposes, or were within another country’s
social security system) by virtue of the
provisions of an international social security
agreement.
Employee shareholding vehicles
The OTS recommended
that the tax and National
Insurance treatment
of shares awarded to
internationally mobile
employees should be more
closely aligned with that of
other forms of employment
income.
Ownership Trusts (see page 7). The new
vehicle is not designed to provide any
further tax advantages over and above those
available for existing models.
Views are sought on the level of demand
for such a vehicle. Responses will determine
the government’s next steps and a further
consultation will be held to seek views on the
detail.
HMRC is considering implementing a
proposal put forward by the OTS for a new
‘employee shareholding vehicle’.
Its aim is to enable companies to manage their
employee share arrangements and create
a market for employees’ shares, with less
administrative burden and at a reduced cost
compared with current ownership vehicles,
such as Employee Benefit Trusts or Employee
1
Business Update
Recent changes to
employment taxes
Over recent months there have been a number of government consultations and
other developments covering employment taxes. We summarise some of the key
developments.
Expenses and benefits
In June 2014, HM Revenue & Customs
(HMRC) issued four consultation documents,
which closed for responses on 9 September.
The consultations cover key areas of
simplification that were recommended by
the Office of Tax Simplification (OTS) and
which, in the 2014 Budget, the government
announced its commitment to take forward.
Legislation is expected to be included in
Finance Bill 2015. The four areas are:
yy Replacing the dispensation regime with
an exemption for qualifying expenses that
are paid or reimbursed by employers.
The government is therefore proposing
that qualifying expenses reimbursed by
employers will be exempt from income
tax and National Insurance contributions
(NICs), such that no P11D reporting will
be required.
HMRC has announced
that for employers with
50 or fewer employees,
automatic late filing
penalties for RTI
submissions will be
deferred until
6 March 2015.
2
Whilst the legislation to implement this
proposal may be in place by April 2015,
it is likely that the new rules will come
into force at the start of a later tax year
(probably 2016/17) to allow employers
and HMRC time to prepare.
yy Abolition of the £8,500 threshold for
lower paid employment and form P9D, so
that all employees are taxed on benefits
in kind on the same basis. However,
the consultation does seek to ascertain
whether there are particular groups of
people or business who are adversely
affected and who might need some
protection.
yy The introduction of a statutory exemption
for “trivial” benefits in kind. Currently,
although employers can apply to HMRC
for agreement to exclude certain benefits
from being reported on the basis that they
are trivial, the difficulty is that neither the
legislation nor HMRC defines what counts
as a trivial benefit.
yy Voluntary payrolling of taxable
expenses and benefits in kind. Some
employers already payroll benefits
under arrangements individually agreed
with HMRC, but there is currently no
legislative framework.
Travel and subsistence
At the end of July 2014 the government
announced a two-stage review of the tax rules
on travel and subsistence expenses. The first
stage of the review is designed to improve
the government’s understanding of the
commercial realities of travel and subsistence
payments, such as the circumstances in
which employers pay travel and subsistence
expenses and how tax and other factors
November 2014
influence commercial decision making in this
area. The government is expected to report
back on its initial findings in the Autumn
Statement.
In the second stage of the review, the
government intends to establish a working
group to assist in producing a new set of
principles upon which the rules of a new
travel and subsistence tax regime will be
based. These principles will be based on the
findings from the first stage of the review. The
government intends to report on this at the
2015 Budget.
Employment status review
The OTS has also been tasked by the
government to review the notoriously
complex dividing line between employment
and self-employment and to consider
whether it is drawn in the right place and in
the right way. A report back is expected at the
2015 Budget.
Company car advisory fuel rates
HMRC’s advisory fuel rates applicable to
journeys from 1 September 2014 are set out
in Figure 1 and Figure 2 below. For one month
following the date of change, employers may
use the previous or the new rates. These
rates are those at which an employer can
reimburse an employee for business journeys
in a company vehicle without any income tax
or NICs charges arising. The rates can also be
used for VAT recovery purposes, as long as
valid VAT receipts are retained.
Hybrid cars are treated as either petrol or
diesel cars for this purpose.
Late filing penalties under RTI
HMRC has announced that for employers
with 50 or fewer employees, automatic late
filing penalties for Real Time Information
(RTI) submissions will be deferred until
6 March 2015. Larger employers are
subject to the penalty regime from
Tax-free childcare
A new tax-free childcare scheme is expected
to replace the existing childcare voucher
scheme in autumn 2015. Employees who
are already in a current voucher scheme can
remain in it until their child reaches the age
of 15, should they so wish.
Under the new scheme, which will be
administered by National Savings &
Investments, eligible families will have 20%
of their yearly childcare costs paid for by
the government, up to £2,000 per child.
One of the advantages of the new scheme
is that it will be open to all single parents
and couples who work eight or more hours
per week. This includes the self-employed
and those who pay for Ofsted-registered
childcare for a child under the age of 12 (or
16 if the child is disabled). The employer, as
well as the employee, will be able to pay into
an employee’s childcare account under the
new scheme.
6 October 2014. Employers should be aware
that irrespective of this relaxation penalties
may still currently apply for late payment of
PAYE/NICs and for incorrect returns.
Late filing penalties are limited to one penalty
per month irrespective of the number of
returns filed late, as shown in Figure 3 below.
National Minimum Wage
The rates increased from 1 October 2014.
These are shown in Figure 4 below.
The apprentice rate applies to apprentices
aged 16 to 18 and those aged 19 or over who
are in their first year. All other apprentices are
entitled to the National Minimum Wage for
their age.
Fig. 3
Number of
employees
Monthly
penalty
1-9
£100
10-49
£200
50-249
£300
250+
£400
Fig. 1
Engine size
Petrol
LPG
1,400 or less
14p
9p
1,401 cc to
2,000 cc
16p
11p
Over 2,000 cc
24p
16p
Fig. 4
Age
Hourly rate
21+
£6.50
18-20
£5.13
Under 18
£3.79
Apprentice rate
£2.73
Fig. 2
Engine size
Diesel
1,600 cc or less
11p
1,601 cc to 2,000 cc
13p
Over 2,000 cc
17p
3
Business Update
International action on
profit shifting
As tax planning by multinationals has become more sophisticated, gaps between
domestic tax systems have become more apparent. In addition, the development
of the digital economy has meant that businesses are more mobile than ever
before. There are concerns that multinationals have been exploiting gaps in
national tax laws to divert profits to low tax jurisdictions, where the business
has little or no real activity, in order to minimise or eliminate corporation taxes.
The Organisation for Economic Co-operation
and Development (OECD) is looking to
tackle this issue through its Base Erosion and
Profit Shifting (BEPS) Project, which aims to
reform international tax rules to prevent tax
avoidance.
The OECD is keen that its Model Tax
Convention adequately deals with the gaps
in tax law, to ensure that multinationals do
not exploit tax treaties to benefit from double
non-taxation. In July 2013, it published an
Action Plan on BEPS, which proposed a
number of changes to the international tax
system, including:
yy Reviewing the application of existing
international tax rules to the digital
economy (ie online businesses).
yy Developing treaty anti-avoidance
provisions to deal with hybrid entities and
hybrid instruments.
yy Developing recommendations for
countries to deal with controlled foreign
companies, interest deductibility, treaty
abuse and hybrids.
yy Improving information exchange,
including spontaneous exchange in some
cases.
yy Improving dispute resolution mechanisms.
yy Broadening the definition of permanent
establishment, with particular focus on
commissionaire distribution models.
4
yy Amending the transfer pricing rules,
including broadening the definition
of intangibles, and documentation
requirements.
yy Developing recommendations for
reporting business restructuring and tax
planning arrangements.
However, changes to information exchange
and improved dispute resolution would
require amendment to UK domestic
legislation and/or double tax agreements.
yy Developing a multilateral instrument
under which countries can implement the
Action Plan proposals.
The Action Plan has been favourably received
by government, and was endorsed by the
G20, which includes the UK. HMRC has
subsequently published the UK’s priorities in
the BEPS Project, which again endorses the
OECD Action Plan.
The first set of reports and recommendations
have been issued during the course of 2014.
Country-by-country reporting
The Action Plan and the reports do not
propose any radical change, but instead rely
on amending and strengthening existing
mechanisms such as transfer pricing,
controlled foreign company and permanent
establishment rules.
The UK already has the framework in place
around which the Action Plan is built. UK tax
legislation specifically incorporates the OECD
Transfer Pricing Guidelines, and HM Revenue
& Customs (HMRC) states that it follows
the commentary to the OECD Model Tax
Convention when interpreting other areas
of legislation. Any changes made to these will
therefore automatically be dealt with in the
UK.
The overall objective of the BEPS initiative
is to ensure that profits are taxed where
economic activities generating the profits are
performed and where value is created.
In order to give a better indication of the
location of the economic activity of a
multinational group, the OECD proposes
a two-tiered reporting structure: a ‘master
file’ providing high-level information about
the global business, and local country files
with information relating to each entity in the
group (country-by-country reporting).
The master file would include details of the
group’s organisational structure together with
a description of its business, its intangibles,
intercompany financial activities, transfer
pricing policies, and its financial and tax
positions.
November 2014
A model country-by-country reporting
template was prepared in early 2014 and
was approved by the G20 at their meeting in
September. Under the model template, the
following information is required for each
entity on an annual basis:
yy The total income tax paid to all other
countries in the relevant tax year;
yy Place of effective management;
yy Stated capital and accumulated earnings,
as reflected on the year end balance
sheet;
yy Business activity;
yy Revenue, taken from the statutory or
audited financial statements of the
company;
yy Earnings before income tax;
yy The total income tax paid to the
authorities in the country of organisation
in the relevant tax year;
yy Amount of withholding taxes paid
on payment received from the other
entities (excluding employment related
withholding taxes);
yy Number of employees;
yy Total employee expenses;
yy Book value of tangible assets, excluding
cash and financial assets; and
yy Intercompany payments of royalties,
interest and service fees.
Reporting will commence from 1 January
2015, and the deadline for filing the template
is expected to be one year from the tax year
end of the parent company.
The extensive information and level of
detail required will significantly increase the
administrative and compliance burden for
multinational companies, and will represent a
significant expansion of information provided
on a corporation tax return.
Companies will need to consider how they
will prepare for the new reporting template,
and existing data gathering and financial
reporting systems may need to be reviewed
and updated accordingly.
The extensive information
and level of detail required
will significantly increase the
administrative and compliance
burden for multinational
companies.
5
Business Update
Our survey of UK
entrepreneurs
The inaugural Saffery
Champness survey of
entrepreneurs carried
out earlier this year
revealed that UK
entrepreneurs are largely
confident about the
future prospects for their
businesses. Indeed over
84% of respondents to
our survey were either
very or quite confident
that they would achieve
their business objectives
over the coming year.
Only 5% were not
particularly confident.
For 26% of
respondents the
availability of skilled
labour was the biggest
challenge.
6
In terms of growth, 52% of respondents had
increased their workforce over the past year
and 67% of respondents had seen an increase
in turnover.
Interestingly, 68% of those surveyed said
they would be concentrating on organic
growth over the coming year and had
no intention of either selling or acquiring
businesses. A quarter of those we surveyed
did plan on making business acquisitions over
the next 12 months.
Finally, we asked entrepreneurs how they
would vote in a referendum on whether the
UK should leave the EU: 17% said they would
vote to leave. 53% of entrepreneurs believed
that the UK’s relationship with Europe is
important to the success of their business.
28%
Employees are the key to innovation
and business growth.
To support their growth, 29% of respondents
saw customers as key; believing that working
with their customers was the most important
way of fostering business innovation and
growth. Employees were a very close second
(28%). These results highlight the importance
of effective customer and employee
engagement – of maximising the resources
that are actually very close to hand.
We asked those we surveyed about the most
important challenges they faced in terms
of the success of their business. For 27% of
respondents the quality of the management
team was fundamental. For 26% of
respondents the availability of skilled labour
was the biggest challenge. The economy was
the most important challenge for 19% of
respondents.
Interestingly, only 39% of those we surveyed
believed that government incentives to
encourage investment in small business are
effective.
The entrepreneurs we surveyed also
preferred more traditional forms of business
funding. While only 7% had explored
crowdfunding over the past year, 35% of
entrepreneurs considered a bank loan as a
means of funding their business and 28% had
considered personal funding of their business
over the past year.
84%
Very or quite confident
that they will achieve their
business objectives over
the next 12 months.
5%
Not particularly
confident about
achieving their
objectives.
34%
Said their workforce
increased by over 5%
over the past 12 months.
November 2014
Employee ownership:
new opportunities for succession planning
The Nuttall Review, published in 2013, highlighted how employee ownership
can help companies become more successful by promoting greater commitment
and productivity from their employees, who feel greater loyalty to a business in
which they have a personal stake. Recognising the potential benefits, Finance
Act 2014 introduced important new tax reliefs that should make it easier to
transfer a company’s ownership to an Employee Ownership Trust (EOT).
The potential advantages of employee
ownership are widely recognised, but the
practical issues, in addition to tax implications,
associated with transferring shares to a
large number of employees have proved
one of the greatest obstacles to a more
widespread adoption of this model. One
means of sidestepping the problem is to hold
shares through a trust for the benefit of the
employees and the reliefs introduced by
Finance Act 2014 are intended to facilitate
indirect share ownership.
Capital gains tax relief for sellers
From 6 April 2014, an individual disposing
of shares to a qualifying EOT will be treated
as making the disposal at nil gain, nil loss
so that no capital gains tax (CGT) liability
arises on the disposal, subject to a number of
conditions:
yy The shares must be in a trading company
or the holding company of a trading group;
yy The EOT must acquire a controlling
interest during the tax year; and
yy The taxpayer and connected persons
must not have made a disposal of shares
that qualified for this relief in an earlier
tax year.
In addition to the CGT relief, the disposal of
the shares into the EOT will be exempt
from any inheritance tax charges. There will
however be a liability to Stamp Duty on the
sale of the shares.
Income tax relief for employees
Since 1 October 2014, employees of
companies owned by EOTs have been able
to benefit from an income tax exemption in
respect of bonus payments made to them of
up to £3,600 per annum.
All employees with at least 12 months’ service
must be entitled to benefit, but the company
has discretion to set the amount of the bonus
by reference to percentage of salary, length
of service or hours worked. The payment
must be a genuine bonus rather than part of
the employee’s regular salary and there can
be no arrangement in place for the employee
to forego part of their salary in exchange for
payment of a bonus.
Qualifying trusts
To satisfy the conditions for relief, the EOT
must be established for the benefit of all
employees on the same terms. In addition,
certain key participators must be excluded
from being beneficiaries of the trust.
The EOT must hold more than 50% of the
company’s ordinary share capital which
carries more than 50% of the voting powers,
rights to profit and assets available on a
winding up.
A CGT charge may arise on the trust in the
event that the qualifying conditions are
breached.
Transitional rules apply which may enable
existing Employee Benefit Trusts (EBTs) to
qualify as EOTs.
Next steps
The exemption relates to income tax only
and Class 1 National Insurance contributions
will still be payable on the bonus by both the
employee and the employer.
Corporation tax
Any tax-free bonuses paid to employees will
be deductible by the company in computing
its corporation tax liability.
An EOT presents another option for business
owners considering their exit strategy,
particularly those who do not see themselves
passing the business to the next generation
of their family, and may be an attractive
alternative to a trade sale or management
buy-out.
However, there are practical considerations
as to whether the new measures will work as
intended, including whether the terms of the
trust would unduly constrain the ability to
raise funds to buy out the owner.
7
Business Update
Amendments to FRS 102
are a step in the right direction
When the ‘new UK
GAAP’ accounting
standard, FRS 102,
was originally published
it was known that
amendments would be
made in relation to debt
and other financing
arrangements. The
Financial Reporting
Council (FRC) has now
finalised its amendments
to the classification of
certain debt products.
These changes will allow
more of these items to
be classified as ‘basic’,
which eliminates the
requirement for them to
be fair-valued.
The FRC has also concluded on the
accounting for hedging transactions. The
amendments are practical with useful
examples and in theory should make
hedge accounting easier to achieve. These
amendments are effective with the rest of the
standard for accounting periods commencing
on or after 1 January 2015.
The ‘basic’ principle
One of the fundamental principles within
FRS 102 is that debt instruments must be
classified into one of two camps; either basic
or other. If an instrument meets the basic
definition, it is held at amortised cost (loan
principal minus repayments) on the balance
sheet. If it fails to meet the definition, it
must be held at fair value, with fair value
movements taken through profit and loss (or
‘income statement’ in the new terminology).
The recent amendments to FRS 102 have
expanded the criteria for classification as
basic. This is seen as a positive change, as it
means that many commonly occurring loan
arrangements can continue to be presented
in a similar manner to that under current UK
GAAP, and without the added volatility of fair
value movements going through the income
statement. The criteria for classification as
basic have been amended as follows:
yy Interest rates on basic debt products
may now include positive fixed or
positive variable rates. They can also be
a combination of a positive or a negative
fixed rate and a positive variable rate. This
would allow a product with an interest
rate of LIBOR plus 200 basis points
or LIBOR, less 50 basis points, to be
classified as basic. However, an interest
rate of 500 basis points, less LIBOR,
would render a product non-basic, since
the variable rate is negative.
8
yy Loan repayments or interest rates (but
not both) may be linked to a “single
relevant observable index of general price
inflation”, eg the Retail Price Index (RPI)
or Consumer Price Index (CPI), in order to
be classified as basic. However, an interest
rate of five times RPI would breach the
criteria because leverage of such rates is
not permitted. Further, the index must
be an index of general price inflation; the
standard specifically identifies house price
inflation as not being a measure of general
price inflation, as it relates only to inflation
for residential property.
yy Other amendments allow for the interest
rate of a basic instrument to vary over the
life of the loan under certain conditions,
for example a change in LIBOR. Provisions
that permit the extension of the term of
the loan are acceptable for the instrument
to be classified as basic. However, any
contractual provisions that could result
in the holder losing the principal amount
would render the product non-basic.
The standard does clarify that debt
subordinated to other debt is not such a
provision.
yy Finally, certain prepayment provisions
or clauses to put the loan back to the
issuer before maturity must not be
contingent on future events (other than
in specific circumstances, for example
loan covenant violations), otherwise it
will fall to be classified as non-basic. To
be clear, if a provision is included in a loan
agreement requiring compensation for
early termination, it does not itself trigger
a breach of this condition.
In a helpful addition to the standard, some
illustrative examples are used to assist in the
classification of financial instruments,
see Figure 1.
November 2014
Hedging simplified
Many businesses mitigate common business
risks, such as exposure to interest rate or
foreign exchange movements, by utilising
swap contracts or other derivatives. These
arrangements are often known as hedging
relationships.
A hedging relationship consists of:
yy A hedged item, eg the risk of variability
in interest payments on a variable rate
loan or foreign exchange risk on a future
forecast transaction; and
yy A hedging instrument, eg an interest
rate swap or a foreign exchange forward
contract.
FRS 102 specifically requires most commonly
occurring hedging instruments such as
options, rights, futures and interest rate
swaps to be accounted for as non-basic.
They must therefore be held at fair value and
revalued to fair value at each balance sheet
date. This is true whether hedge accounting
is applied or not and in many cases will result
in a transitional adjustment upon transition
to FRS 102. Fair value movements upon
revaluation will introduce volatility into the
income statement.
In many cases it may be possible, although
it is optional, to account for the relationship
as a hedge. The amendments to FRS 102
distinguish between two types of hedges
(note that a net investment in a foreign
operation would be accounted for similarly to
a cash flow hedge):
yy Fair value hedges, which reduce exposure
to changes in the fair value of a financial
statement item. An example would be a
hedge against fair value movements on a
non-basic debt instrument. Movements in
the fair value of both the hedged item and
the hedging instrument are recognised
through the income statement in the
same period. They will offset to the extent
that the hedge is effective. This reduces
volatility in the income statement caused
by movements in the fair value of the
hedged item.
yy Cash flow hedges, which reduce exposure
to variability in cash flows attributable to
a financial statement item. An example
would be a hedge against variability in
interest payments on a variable rate loan.
In a cash flow hedge, movements in the
fair value of the hedging instrument are
deferred through other comprehensive
income. They are subsequently recycled
FRS 102 specifically
requires most commonly
occurring hedging
instruments... to be
accounted for as
‘non-basic’.
to the income statement when the hedged
item is realised or a non-financial asset
or liability is recognised. This effectively
brings the recognition of the gain or loss
on the hedging instrument into the same
accounting period as the gain or loss on
the hedged item, thus reducing volatility.
The mechanics of each type of swap are set
out in some useful illustrative examples within
the amendments to FRS 102.
The FRC has responded to feedback on the
original drafting of FRS 102 in these areas
and the result is practical and clear guidance
on what is often seen as a complex area of
accounting.
Fig. 1: examples of financial instruments and their classification explained within the amendments to FRS 102
Example
Classification
1. Zero-coupon loan
Basic
2. Fixed interest rate loan which reverts to the bank’s standard variable interest rate.
Basic
3. A loan with an interest payable at the bank’s standard variable rate plus 1%.
Basic
4. A loan with interest payable at the bank’s standard variable rate less 1%, with the condition that the interest
rate can never fall below 2%.
Basic
5. Interest on a loan is referenced to two times the bank’s standard variable rate.
Non-basic
6. Interest on a loan is charged at 10% less six-month LIBOR over the life of the loan.
Non-basic
7. Interest on a GBP denominated mortgage is linked to the UK Land Registry House Price Index (HPI) plus 3%.
Non-basic
9
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J5554.
Geneva
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1207 Geneva, Switzerland
T: +41 (0)22 319 0970
Guernsey
PO Box 141, La Tonnelle House,
Les Banques, St Sampson,
Guernsey GY1 3HS
T: +44 (0)1481 721374
Harrogate
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Harrogate HG1 5RX
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High Wycombe
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High Wycombe HP13 5DR
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Zurich
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8032 Zurich, Switzerland
T: +41 (0)43 343 9328
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