Update: 899 Penalty Tax Will NOT Go Forward - Secretary Bessent Claims Mission Accomplished!
Prologue
I have written about the proposed IRC S. 899 Tax titled:
“Enforcement Of Remedies Against Unfair Taxes”
Take YOUR Money And Run: Understanding The Proposed § 899. ENFORCEMENT OF REMEDIES AGAINST UNFAIR FOREIGN TAXES
The Proposed S. 899 Penalty Tax On U.S. Source Income And The Decision To Renounce U.S. Citizenship
It now appears that the S. 899 tax will NOT be included in the “Big…
Join our Financial Services tax webinar on 9 November 2022 at 08:30 to discuss legislative developments, court cases and practice - Banking blog
Join our Financial Services tax webinar on 9 November 2022 at 08:30 to discuss legislative developments, court cases and practice – Banking blog
We would like to invite you to our half yearly webinar where we provide key updates and discuss recent tax developments that are important for the financial services industry on Wednesday 9 November 2022 at 08:30.
The focus of the webinar will be on the following topics:
The impact of the recent vote on Swiss withholding tax reform
Recent EU Court of Justice decisions and national and…
Applications for all SRDP Pillar 2 schemes will be delayed until March at earliest, contracts will not be issued until 2016, there is a very short window for applications for those schemes which do open this year and as a result it is unlikely that many applications will be processed. There is effectively a 2 year waiting period until the majority of land owners or managers are likely to see a contract in 2017, leaving a longer period still until works are completed and payments made. There will be 400 contracts for designated sites issued in the next few weeks.
Agri Environment Climate Scheme
The focus of the farming industry’s attention at least in the Western Highlands where the Greening requirements don’t have much relevance will be on the Agri Environment Climate Scheme.
The AECS (now pronounced “aches” as in aches and pains) is similar to schemes we have seen previously but is now more competitive, more targeted and has a limited budget.
Application Timeframes
Applications for the first round of AECS will be submitted from mid March until 29 May 2015. SGRPID are aware that this is a short period but believe that by extending it they would not be able to issue contracts at the beginning of 2016. The greatest challenge facing land managers and advisers is that of getting an application in on time, with many already being stretched to the limit by the demands of mapping and Pillar 1. There will not be many applications going forward this year.
The key message to farmers and land managers is that they must get on line and register now at https://www.ruralpayments.org
AECS Priorities
The SRDP priorities towards which the scheme has been targeted have seen few changes although SGRPID has now launched its new online service which they intend to build on over time
The scheme is targeted at
- vulnerable species, habitats and ecology networks
- the protection of designated sites
- reducing greenhouse gas emissions and securing carbon sinks
- improving water by decreasing diffuse pollution
- natural flood risk management
- organic farming
- controlling invasive non-native species
- preserving historic environments
- improving public access
AECS Application Process
The process of applying for SRDP management grants has 6 key steps
1. Consult the website
2. Use the targeting tool
3. Complete the Farm Environmental Assessment
4. Online Application
5. Upload Supporting Documents
6. Application Scoring and Assessment
Eligibility
Those eligible are farmers, crofters, common grazing committees and other land managers. Third party works for necessary capital works on behalf of consenting land owners will also be possible.
Only operations on mapped land will be eligible.
The online site for all schemes is here https://www.ruralpayments.org/publicsite/futures/topics/all-schemes
The site allows farmers to enter their holding number to see what options and items are available on their holding.
If famers or land managers wish to proceed outside the targeting for their area they will require endorsement from SEPA, SNH or other appropriate bodies. For anyone in any doubt as to whether they are dealing with a protected or designated area which might have requirements outside the targets for their area the SNH website is http://www.snh.gov.uk/protecting-scotlands-nature/protected-areas/. Other reasons for departing from the priorities for an area should be discussed.
New Requirements for AECS
The first change many farmers will note is the requirement for a Farm Environment Assessment Map. This must be accompanied by a descriptive table detailing all the elements on the map. It will also be accompanied by a Diffuse Pollution Risk Assessment.
There is funding available of up to £500 for the preparation of plans payable on submission of a successful plan. This is a one-off exercise. If a plan were submitted unsuccessfully no payment would be made until the plan had been altered to make it successful.
SGRPID point out that in many cases pre-existing plans may be brought up to date with various additions
There is also the possibility that a “Diffuse Pollution Steading Assesment” will be required although this is unlikely on the West Coast.
The combined documentation should show management operations and investments required to contribute towards AECS priorities
AECS Thresholds
AECS has two levels of funding
Level 1 is up to £75 000 over the duration – for AECS options and public access options – which will be dealt with by SNH
Level 2 is over £75 000 for large or multiple partner collaborative schemes with multiple landscape objectives.
Scoring and Assessment
The Scoring and Assessment Process is not yet available but should be made available by Mid March.
The initial eligibility assessments will involve
- a detailed desk assessment
- a site visit
- and/or a discussion by phone with the applicant
Applicants must be able to demonstrate feasibility of delivery. The awarding body will be looking to check applicants’ understanding of the application and the requirements of the options applied for. They will also be checking that the applicant understands how and whether the plan will fit in with the current land management and usage. The focus is on ensuring that the applicant and not the land manager or the person writing the application understands all the requirements. A gap in that understanding will mean that the plan doesn’t go through. The only issues that may be addressed at that stage will be very minor ones or those that involve low level detail :– mistakes in calculations or mislabelling as examples.
Requirement for a Management Diary
There is also a new requirement to keep a management diary with all the relevant details of scheme management. This should demonstrate understanding and competence with regard to the management plan.
The diary will only be checked on those cases selected for inspection. A minimum of 5% of cases are selected for inspection from the available number each year. SGRPID prefer this approach to that on checking all diaries on an annual basis.
The management diary template will be part of the package of contract documents that is sent out to successful applicants.
Management plans should go on the 2016 SAF form and not on the 2015 SAF form. The only exceptions to this will be the 400 designated sites, applications for which will have to go on to this year’s SAF, the contracts for these sites will be out in the next few weeks.
Payments are conditional on meeting cross-compliance requirements for both LFASS and AECS. These requirements have been streamlined and are now reflected in the Greening requirements.