Finance Bill 2018 contains measures designed to counter schemes in which companies use related party transactions to achieve a step-up in the base cost of an intangible fixed asset. Clearly anti-avoidance in nature, the provisions will affect any intangibles transaction involving non-monetary consideration.

Looking further ahead, Finance Bill 2019 is expected to extend the circumstances in which tax must be deducted at source from royalty and other payments. This article takes a look at both of these developments and anticipates a more comprehensive review of the intangibles rules later in 2018.