Monthly Archives: December 2016

ALMR, NATIONAL PROOF OF AGE STANDARDS SCHEME (PASS)

ALMR

NATIONAL PROOF OF AGE STANDARDS SCHEME (PASS)

Government support for PASS identification scheme welcomed

PASS has welcomed the Government’s support of the National Proof of Age Standards Scheme (PASS) and has urged the licensed hospitality sector to support the scheme by accepting PASS cards in their venues.

The Home Office today launched a new campaign to encourage people to leave their passports at home and to rely upon other secure and recognised means of identification, in a bid to tackle passport fraud. Endorsing the scheme,

PASS Interim Chair (and ALMR Chief Executive) Kate Nicholls said:

“The PASS scheme is a fantastic, industry-driven scheme and it is one which we encourage retailers to support. The card itself is very secure with no successful forgeries to date. It is endorsed by the Home Office and we are encouraging venues to accept the card as the best method of ID. Phone-based apps for identification are proving flawed and insufficient against Home Office criteria, but PASS ticks every box.

“Not only are lost or damaged passports an inconvenience, they are enormously expensive to replace. Half of all lost passports, a considerable number, occur when holders take them to pubs, bars or nightclubs.

“There is an opportunity here for the sector to support its customers and to lead a fundamental change in attitudes regarding acceptable forms of ID. We echo the Home Office’s encouragement of customer to sign up to the scheme and leave their passports at home. This can only happen if there is widespread acceptance of PASS cards as the preferred form of ID across the UK.”

ALMR, Future Shock reveals causes for optimism amid challenges 

ALMR

 

Future Shock reveals causes for optimism amid challenges 

Brexit and rising costs will present out of home eating and drinking operators with big challenges in 2017—but new openings growth, technology and the Night Tube are among the reasons to be optimistic about the sector’s future.

Those are among the findings in the second issue of Future Shock, a major new collaboration between CGA Peach and the ALMR that provides a ‘state of the nation’ report into the eating and drinking out sectors and rounds up important new insights into consumer, supply chain, drinking and economic trends for operators.

The report shows that operating costs now account an average of nearly half (47.7%) of turnover for businesses in the sector, with rising property and staff costs an increasing challenge for many of them. Another staffing issue has arisen from Brexit and the resulting uncertainty of the future of EU migrants, who account for close to half (46%) of the workforce in hospitality and tourism.

But the Future Shock report also demonstrates how technology, and social platforms like Facebook, Twitter and Instagram in particular, are now integral to the planning of nights out, and can be harnessed by operators to increase their profile and sales. Another opportunity comes from the introduction of the Night Tube in London, with CGA Peach data indicating that there are more than 3,000 licensed premises within 500m of stations on the lines that now operate around the clock.

Other key stats revealed by the exclusive report include:

  • The number of food-led licensed venues in Britain has increased by 13.5% in the five years to September 2016—compared to a 12.4% drop in the number of drink-led venues
  • Nearly half (46%) of British consumers say they now eat out at least weekly. A third (33%) say they drink out at least weekly
  • Three in five (60%) consumers say they trust online reviews, rising to 71% of 18 to 24 year-olds—an indication of the huge importance of platforms like TripAdvisor and social media
  • Half (52%) of British consumers think the government’s planned sugar tax on soft drinks is a positive change—but only a fifth (19%) are likely to reduce their sugar consumption as a result.

CGA Peach business unit director Jamie Campbell said: “It has not been an easy ride for operators in the eating and drinking out markets in 2016, and CGA Peach’s research shows that any growth is hard won in an intrinsically flat market. And with the seismic shock of Brexit yet to play out in full, and property and staff costs still rising, conditions aren’t likely to get much better in 2017. But as Future Shock shows, there are still plenty of growth opportunities for the leading brands over the coming year. By good use of technology, smart marketing and giving consumers the food, drinks and experiences they want—plus, crucially, some support from government over industry issues—operators can look forward to 2017 with optimism.”

ALMR chief executive Kate Nicholls said: “The National Living Wage, business rates reform, Brexit—there are a lot of issues that eating and drinking out operators will need to stay on top of as we enter 2017, and the ALMR will be campaigning loudly and proudly for the sector within government.

“This latest Future Shock report provides important intelligence for that work, and presents a one-stop-shop for information for everyone interested in the sector. It is a balanced and honest health check—a digest of some of the challenges we all face but also of the many reasons we have to be proud of our creative and economically important work.”

The ‘Future Shock’ report draws on CGA Peach’s portfolio of industry-leading research sources in the out-of-home eating and drinking sectors, including the Coffer Peach Business Tracker, Brand Track, Trading Index, Pricing Index and Alix Partners Peach Market Growth Monitor. The research is complemented by the ALMR’s own data from sources including its annual survey of members with Christie + Co.

The ‘Future Shock’ report is published twice a year by CGA Peach and the ALMR. Partners on the research are CACI, CPL Training Group, RSM, Heineken, WhyNot!, Barclays, Coca-Cola European Partners and Sky. For more information about Future Shock, please contact CGA Peach business unit director Jamie Campbell at jamie.campbell@cgapeach.co.uk.

Record-breaking Year for Gin as Sales Surpass £1bn

Record-breaking Year for Gin as Sales Surpass £1bn

Retailers, bars and pubs sold the largest volume of gin on record in 2016, six months ahead of forecasts

A report by the Wine and Spirit Trade Association (WSTA) shows that the UK’s love of gin continues to grow, as sales of the spirit in shops, supermarkets and off licences have increased by 68 per cent since 2012.

According to the report, the market is currently booming due to customers opting for more premium and artisan options.

Exports have also been boosted by the overseas popularity of franchises such as Downton Abbey and James Bond, which helped to sell £159m worth of British gin to America in 2015, claims WTSA. Gin exports to the USA have risen by 553 per cent in the last decade.

40 new distilleries have opened in 2016, says HMRC, with some experimenting with ingredients like seaweed, acorns, grape skins, acorns and ants.

WSTA reports that three out of every four bottles sold around the world are produced in the UK.

Miles Beale, chief executive of WSTA said, “There are many reasons why people may not feel like celebrating 2016, but the WSTA are pleased to give you something happy to reflect on – 2016 can now be remembered as the ‘Great British Gin Take Off’.”

He added, “We hope that government supports our innovative gin makers who have driven an extraordinary increase in UK exports, up 166 per cent since 2000. We would like to remind government that cutting excise duty boosts business and brings more money into the Treasury.

“Let’s make sure gin continues to boom in 2017.”

 

UK manufacturers had the opportunity to quiz environment secretary Andrea Leadsom on the government’s plans to boost post-Brexit exports at the Food and Drink Exporters Association’s Network Forum on 14th December

Andrea Leadsom will be briefing the delegates on the recently announced International Action Plan for Food and Drink, which is designed to boost the sector’s exports by £2.9bn.

Elsa Fairbanks, director at FDEA said, “Brexit has given food exporters a short-term boost due to the falling value of the pound. However, a recent FDEA survey showed our members are concerned that on-going economic uncertainty in the run-up to Brexit and further currency movements will make exporting more challenging.

“There are also questions around the government’s understanding of the complexities of food and drink exporting and how this will be managed if freedom of movement across the EU is not guaranteed in the sector’s biggest markets.

“They will be seeking reassurance from Mrs Leadsom about the details of the government’s action plan and what it will specifically mean for current and potential UK exporters.”

The Westminster-located forum is open to both members and non-members and offers a day of export advice to help food and drink businesses review and build an export strategy in the post-Brexit world.

Delegates will be able to learn more about exporting from seasoned exporters, including Walkers Shortbread, Clipper Tea and Propercorn.

Elsa Fairbanks added, “At the moment, our key piece of advice to exporters is to use the time in the run-up to leaving the EU to build strong relationships with existing and potential customers and to explore new markets around the world. Researching markets and cementing relationships now, will be key to securing future export business.”

For more information or to confirm your attendance visit ukfdea.com.

Punch agrees to £402.7m takeover offer:

Punch agrees to £402.7m takeover offer:

Thu 15th Dec 2016

Punch has agreed to a £402.7m takeover offer from private equity firm Patron Capital Advisers LLP and Dutch brewer Heineken. Patron and Emerald Investment Partners revealed rival offers for Punch on Wednesday (14 December), sending shares in the pub company surging by 40%. Punch is the second-largest pub chain in the UK by number of sites, with about 3,300.

Patron has agreed to pay 180p a share in cash and the offer has  received the support of Punch’s top three shareholders, Glenview Capital, Avenue Capital and Warwick Capital Partners, which control 52.3% of Punch’s issued share capital, and of the Punch directors. In addition, including Punch’s total net leverage as at 20 August 2016 of £1,372.9m (including swap value of £169.7m), the offer implies an enterprise value of £1,775.6m and represents a multiple of approximately ten times Punch’s Ebitda for the 52 weeks ended 20 August 2016.

Under the terms of the offer, once completion has been achieved, Heineken will buy the Punch A securitisation and certain pubs, plus Punch intercompany loans for £305.0m.

The Punch A securitisation is one of the two tranches the company’s debt was split into in 2014 when it completed a significant restructuring of its financial obligations.

The deal would add 3,300 pubs to the 1,100 sites Heineken controls in the UK through its Star Pubs & Bars business.

Punch expanded rapidly in the 2000s but then took a hit from the introduction of the smoking ban in the UK, higher beer duties, and a general downturn in the British pub industry during the financial crisis of 2008.

The company frequently warned in the lead up to restructuring that it could default on its debt pile and eventually agreed a debt-for-equity swap deal in October 2014 with its lenders which gave its bondholders 85% of its equity.

Stephen Green, senior partner of Patron Capital, said: “Our offer creates an exciting opportunity for Punch as a more focused business.

Under private ownership, with strong financial backing, and a commitment to continued investment, pubs and publicans will have our full support to deal with changing market dynamics and provide their customers with the best possible offer.

These are high quality pubs with excellent future potential.” Stefan Orlowski, regional president Europe for Heineken, added: “This transaction is a significant step forward in our strategy to unlock value in the UK pub market.

The performance of our Star Pubs & Bars business clearly shows that well invested pubs, in the hands of skilled and ambitious independent operators, can outperform.

Leveraging our extensive experience will enable us to realise increased potential from the pubs we are acquiring and deliver positive returns to our shareholders.”

Heineken UK managing director David Forde said: “Today’s announcement is a huge vote of confidence in the Great British pub. Our proven track record of success demonstrates that well invested and well-run pubs in the leased and tenanted sector can thrive.

Today’s development is good news for pub-goers across the UK who will see the benefit of better pubs in their communities. We look forward to welcoming new licensees in to Star Pubs & Bars, and to working with them to grow their businesses.”

Punch chairman Stephen Billingham added: “The Punch board and management team have positioned Punch to drive long-term value for shareholders and our recent performance has demonstrated the successful execution of this strategy reflecting the hard work and quality of the whole Punch team.

While the board did not solicit this offer for the company, we believe this is a good outcome for shareholders as the offer provides cash certainty at a significant premium.”

 

PUNCH TAVERNS – CO AGREES TO LOWEST BID: (Langton Capital)

• Patron & Punch announce agree to ‘recommended final cash offer’ for company of 180p per share

• The initial approach (at least the first that was made public) was at 174p

• PUB bid has agreement of 52.3% of shareholders. It says this is irrevocable (but only in the absence of a bid >200p). Q important, that.

• Punch has the agreement of the directors, Glenview, Avenue Capital and Warwick Capital. But only if there is not a materially better offer

• Punch. Bid is not necessarily final and irrevocable agreements are not necessarily irrevocable. Over to you, Mr McIntosh

• Punch bid. Lots of surplus words. Including ‘irrevocable’, perhaps. Also, premia to recent equity share price levels arguably meaningless

• Punch offer c40% premium to 3dys ago but c20% discount to price at which refinancing backed by supportive shareholders in 2014

• Punch. Rival potential bidder Emerald was last seen willing to pay 185p. It would have to top 200p to stay in the game

• Punch. Various premia are mentioned in offer RNS but they mean little in the context of a company in Punch’s position

• Punch is (arguably) extremely valuable in the eyes of a brewer such as Heineken. Punch’s NAV is 285p

• Punch has argued its NAV is fair at 285p. It would take a buyer c20yrs or more to construct such an estate. But bird in hand etc.

• Punch. Bidco says it would have to use some disposal proceeds to fund the aggregate Offer Consideration

• Punch. Patron says re its break-up proposal ‘our offer creates an exciting opportunity for Punch as a more focused business.’ It continues ‘under private ownership, with strong financial backing, and a commitment to continued investment, pubs and publicans will have our full support to deal with changing market dynamics and provide their customers with the best possible offer. These are high quality pubs with excellent future potential.’

• Punch bid. Heineken says ‘this transaction is a significant step forward in our strategy to unlock value in the UK pub market.’ Not sure what solace that is to Punch’s shareholders. It adds ‘the performance of our Star Pubs & Bars business clearly shows that well invested pubs, in the hands of skilled and ambitious independent operators can outperform.’ Ditto.

• Punch. Chairman Stephen Billingham says ‘Punch Board and management team have positioned Punch to drive long term value for shareholders and our recent performance has demonstrated the successful execution of this strategy reflecting the hard work and quality of the whole Punch team. While the Board did not solicit this offer for the company, we believe this is a good outcome for shareholders as the offer provides cash certainty at a significant premium.’ Hum.

• Punch, external comment.

o PMA has industry figures expressing ‘serious concern’ over Heineken’s planned bid as it could disadvantage tenants

o British Pub Federation writes to Competition Commission asking it to scrutinise the takeover

o Greg Mulholland MP warns that the emergence of a giant integrated brewer could be ‘very worrying’. He is reported by the PMA as saying ‘it would not be in the interests of consumers or licensees to have Heineken buying Punch. To have a giant brewing pubco taking on one of the two giant pub-owning property companies would be a huge step backwards and could restrict choice for both licensee and customer alike and this must be referred to the Competition Commission. There is also the danger with Heineken wanting pubs to stock their own products that they would be looking to ‘churn’ existing Punch licensees to be able to do so, which would be completely unacceptable’.

o Heineken already owns 1,049 pubs through its Star Pubs & Bars division. Adding Punch A would take it through 3,000

o Telegraph says ‘shares in Punch surged 7.9pc to 191p yesterday, suggesting traders expect a counterbid to emerge.’

o Punch chairman Stephen Billingham reports Heineken discussions been ongoing for ‘more than a year’

o Billingham says ‘the Heineken-Patron offer has maturity which is available to the shareholders to accept, whereas the Emerald offer does not have that degree of maturity and there is uncertainty over the source of the funding.’ He adds ‘the fact that over 50pc of the register has already signed up is an indication that this deal offers good value to shareholders.’

o Telegraph points out deal will need 75% approval.

Shares at Punch climb almost 40% following takeover bids

Propel

Shares at Punch climb almost 40% following takeover bids:

Shares at Punch have climbed almost 40% after it confirmed it had received two takeover bids. The company’s share price increased 48.5p to 177.00p on Wednesday afternoon (14 December) from the start of trading – up by 37.74%. It confirmed earlier in the day it had received bids from Heineken and an investment fund backed by Punch co-founder Alan McIntosh. Heineken is in advanced talks but the Dutch brewer’s 174p offer has been outshone by an 185p bid from Emerald Investments, which would value the business at £410m. Both parties have until 11 January to make final offers.

If you would like to read the latest Industry News and Corporate Activity, please click on the following link     http://www.propelinfonews.com/selecttemp.php, before 9.00 am for yesterdays News, click on the link after 9.00 am for latest Weekday’s News

Note from Editor:-It would appear that this possible takeover may generate some very interesting situations, possibly beyond the scope of some aspects of the new legislation and the administrators.

There may be questions asked in the House about the legality of certain actions by persons involved, sadly we cannot expand further until or if these questions are raised, but a warning to all lessees make sure you get very good legal advice before taking further actions.

 

December Tax Tips and News

Welcome…
To December’s Tax Tips & News, our newsletter designed to bring you tax tips and news to keep you one step ahead of the taxman.

If you need further assistance just let us know or you can send us a question for our Question and Answer Section.

We are committed to ensuring none of our clients pay a penny more in tax than is necessary and they receive useful tax and business advice and support throughout the year.

Please contact us for advice on your own specific circumstances. We’re here to help!

December 2016

HMRC clarify pre-registration of VAT policy top
HMRC have recently published Brief 16 (2016), entitled Tr eatment of VAT incurred on assets that are used by the business prior to VAT registration. Broadly, the brief aims to clarify when, and to what extent, VAT is deductible and what to do if the correct treatment has not been applied.

A business registering for VAT may recover tax incurred on goods and services before their effective date of registration (EDR). This allows the recovery of VAT against goods and services as long as they are used by the taxable person to make taxable supplies once registered.

Services must have been received less than six months before the EDR for VAT to be deductible. This time limit is a simplification of the rules and means that detailed calculations of the use before and after EDR are not required. This excludes services that have been supplied onwards. VAT on services received within the relevant time limit can be recovered in full.

Goods have a four-year time limit for deduction that is consistent with the general VAT ‘capping’ provisions. Again, this excludes goods that have been supplied onwards or consumed before EDR. However, VAT on fixed assets purchased within four years can be recovered in full.

HMRC believe that the word ‘consumed’ has been interpreted inconsistently over time, particularly in relation to business assets and HMRC. The purpose of Brief 16 is therefore to clarify the policy position, which HMRC stress, has not changed. The policy is as follows:

Subject to the normal rules on VAT deduction:

– VAT on services received within six months of EDR and used in the business at EDR is recoverable in full;
– VAT on stock is deductible to the extent that the goods are still on hand at EDR (for example apportionment may be required);
– VAT on fixed assets purchased within four years of EDR is recoverable in full, providing the assets are still in use by the business at EDR.

Full recovery only applies if the business is fully-taxable. Businesses who are partly-exempt, have non-business activities, or need to restrict VAT deduction for any other reason, will need to take that into account when calculating deductible VAT.

HMRC will accept corrections for overpayment of VAT in the following circumstances:

– the business has reduced the VAT it deducted on fixed assets, to account for pre-EDR use;
– HMRC have raised an assessment of tax to account for pre-EDR use of fixed assets;
– HMRC have reduced a repayment claim to account for pre-EDR use of fixed assets.

HMRC will consider claims for repayment of penalties and interest charged as a result of assessments.

Employment Allowance consultation launched top
HMRC have launched a technical consultation on proposals to restrict the Employment Allowance (EA) from employers of ‘illegal workers’. The consultation is open for comments until 3 January 2017.

Budget 2016 announced that from April 2018, the EA would be removed for one year from those who receive civil penalties for employing illegal workers. Broadly, the allowance entitles the vast majority of businesses, charities, and community amateur sports clubs to a reduction of up to £3,000 per year on their employer National Insurance Contributions (NICs) bill. Whilst the allowance has very broad eligibility, the Government believes that those who break the law by employing illegal workers should not benefit from it. The purpose of the restriction therefore is to ensure the allowance focuses on employers who are providing legitimate employment.

The proposed change will only impact employers who have received a civil penalty from the Home Office for employing workers subject to immigration control and have exhausted their Home Office appeal rights in relation to that civil penalty. Early estimates suggest that around 2,000 employers will be affected.

Voluntary living wage increase takes effect top
The official living wage rate has increased by 20p per hour to £8.45 an hour (£9.75 in London), which is higher than the UK-wide official National Living Wage for those over 25, currently set at £7.20, while those under 25 must be paid the national minimum wage (NMW).

The Living Wage is independently-calculated each year based on what employees and their families need to live. Employers can choose to pay the real Living Wage on a voluntary basis but it is currently paid by a third of FTSE 100 companies.

The rates apply to all workers over 18 in recognition that young people face the same living costs as everyone else.

These figures are calculated annually by the Resolution Foundation and overseen by the Living Wage Commission, based on the best available evidence on living standards in London and the UK.

Caps on income tax relief top
In general terms, providing a business is undertaken on a commercial basis with a view to making a profit, tax relief should be available for trading losses incurred. It is usually possible to offset the loss against other taxable income from the same year, or the previous year. Other taxable income may include for example, a former employment (where tax was deducted under PAYE) or a pension.

This relief may be particularly beneficial for someone who is self-employed on a part-time basis. For example, where an individual earns £30,000 a year from employment, and makes a £2,000 loss from his or her part-time business, their tax bill for the year will be based on income of £28,000.

Where a loss is incurred in any of the first four tax years of a new business, the amount of the loss can usually be carried back and offset against total income of the three previous tax years, starting with the earliest year. Therefore, where an individual has paid income tax in any of the previous three years, he or she is likely to be entitled to a repayment of tax. The maximum amount must be offset each year – it is not possible to offset a proportion of the loss in order to spread the loss across three years to take advantage of beneficial tax rates. Again, relief will not be available unless the individual was trading on a commercial basis with a view to making a profit within a reasonable timescale. In practice, this requirement may be difficult to prove in the case of a new business and HMRC may want to see a viable business plan to support a claim.

It is worth noting that the income tax legislation sets out various specific reliefs that may be deducted in the calculation of income tax liability, including reliefs which can be relieved against general income. Before 6 April 2013 there was generally no upper limit on the amount of income tax relief which could be claimed. However, from 6 April 2013 certain restrictions apply to the amount of loss relief available. The primary reliefs affected by the cap are the trade loss reliefs outlined above, property loss reliefs that can be relieved against general income, and qualifying loan interest relief. A small number of other reliefs will also be affected. The cap is set at £50,000 or 25% of income, whichever is greater.

‘Income’ for the purposes of the new cap will be calculated ‘total income liable to income tax’. This figure will then be adjusted to include charitable donations made via payroll giving and to exclude pension contributions – this adjustment is designed to create a level playing field between those whose deductions are made before they pay income tax, and those whose deductions are made after tax. The result, known as ‘adjusted total income’, will be the measure of income for the purpose of the cap.

The cap will apply to the year of the claim and any earlier or later year in which the relief claimed is allocated against total income. The limit will not apply to relief offset against profits from the same trade or property business.

Anyone wishing to make a claim for loss relief needs to be aware of the time limits for doing so -HMRC must be informed within 12 months following 31 January after the end of the loss-making business year.

December questions and answers top
Q. My wife doesn’t work. Can she transfer her unused personal tax allowance to me?

A. Since April 2015, it has been possible for a spouse or civil partner who is not liable to income tax or not liable above the basic rate for a tax year, to transfer part of their personal allowance to their spouse or civil partner, provided that the recipient of the transfer is not liable to income tax above the basic rate.

The transferor’s personal allowance will be reduced by the same amount. For 2015/16 the amount that could be transferred was £1,060, rising to £1,100 for 2016/17. The spouse or civil partner receiving the transferred allowance will be entitled to a reduced income tax liability of up to £220 for 2016/17 (£212 for 2015/16). Note, however, that married couples or civil partnerships entitled to claim the married couple’s allowance are not entitled to make a transfer.

Q. I am currently in the process of purchasing a property which includes a separate granny annex. Since there is only one title number for the whole property, can I apply for stamp duty land tax multiple dwelling relief (MDR)?

A. Broadly, if the granny annex is an independent dwelling, then it will count for MDR. If it cannot exist independently of the main house, then MDR will not be available.

The HMRC Stamp Duty Land Tax Manual states (SDLTM29955):

‘For the purposes of the relief a “dwelling” means a building or part of a building which is suitable for use as a single dwelling or is in the process of being constructed or adapted for such use.’

Special rules apply to certain types of dwellings, including halls of residence and ‘off plan’ transactions. See the HMRC S tamp Duty Land Tax Manual for further information.

Q. I bought a flat in 2000 and paid £100,000 for it. I left the UK in November 2003 to work overseas and it has been rented out since then. I have not returned to the UK since I left and I now live permanently in France. I am thinking of selling my UK flat, which is now valued at £300,000. What are the tax implications of doing this?

A. The tax implications for non-UK residents selling UK residential properties changed in relation to disposals after 5 April 2015. Prior to then, there would have been no UK capital gains tax to pay. Unfortunately, after that date, the disposal will be subject to capital gains tax based on the value of the gain between 6 April 2015 and the date of sale. There are different ways of calculating the gain and you can use HMRC’s online calculator to work out the amount of tax due. You must tell HMRC within 30 days of conveyance, for example no later than 31 July if you convey on 1 July. HMRC may impose penalties where the reporting deadline is missed and interest will be payable on tax not paid by the normal due date. See the HMRC website at https://www.gov.uk/guidance/capital-gains-tax-for-non-res idents-uk-residential-property for further information.

December key tax dates top
19/22 – PAYE/NIC, student loan and CIS deductions due for month to 5/12/2016

30 – Deadline for 2015/16 self assessment online returns to be filed if you are an employee and want tax underpaid to be collected by adjustment to your 2017/18 PAYE code (for underpayments of up to £3,000 only)

Disclaimer
The information contained in this newsletter is of a general nature and no guarantee of accuracy can be given. It is not a substitute for specific professional advice in your own circumstances. No action should be taken without consulting the detailed legislation or seeking professional advice. Therefore no responsibility for loss occasioned by any person acting or refraining from action as a result of the material can be accepted by the authors or the firm.

Howard and Company is the trading name of GM Howard & Company Limited, a company registered in England and Wales. Reg No 5307665. Registered office, Unit 17, Park Farm Business Centre, Fornham St Genevieve, Bury St Edmunds, Suffolk IP28 6TS.