For companies now subject to investigation from an EU State Aid perspective, the potential for repayment obligations are likely to be an unexpected outcome from what many may have regarded as mainstream tax structuring. An outline of the current position is available here.
The UK Government is keen to be seen as taking the lead in implementing the OECD’s recent recommendations to counteract perceived international tax avoidance. No surprise there given next year’s general election, and it is hybrid structures that are first in the firing line. In brief, hybrid structures seek to take advantages of mismatches between the … Continue reading A wrecking ball for tower structures: major reform of hybrid rules announced
The Chancellor today announced three key measures to help the UK tackle Base Erosion and Profit Shifting (“BEPS”). The measures signal the first concrete BEPS related measures intended to be adopted into domestic legislation. The measures are part of the UK Government’s efforts to strengthen anti-avoidance measures and in the process promote fairness in tax … Continue reading BEPS takes centre stage as Chancellor ushers in special ‘Tech Tax’
With all of the focus on next month’s devolution vote in Scotland, it is easy to overlook reports this week suggesting that Northern Ireland’s parliament is likely to be given corporation tax rate setting powers. The debate on whether such a move is desirable and/or compliant with EU law has been rumbling for years. It … Continue reading Northern Ireland: possible corporation tax reduction?
Among the draft Finance Bill clauses recently published were amendments to the UK double tax relief rules (“DTR Rules”) which are likely to be of interest to many UK based corporates with overseas income streams. The general aim of the DTR Rules is to allow relief for foreign tax against UK tax on the same … Continue reading Changes to double taxation relief rules to counter avoidance
The Government is withdrawing income tax relief for payments of patent royalties by individuals to combat perceived abuse of these rules. The relief will be withdrawn for such patent royalty payments made from today onwards. This is in stark contrast to the introduction, from April 2013, of a new “Patent Box” regime for companies. The Patent Box regime will enable companies … Continue reading Patents: time to incorporate?
Previously announced measures in relation to the R&D tax credit and the proposed new Patent Box have been confirmed. The Government intends to introduce an ‘above the line’ R&D tax credit in Finance Bill 2013 to encourage R&D activity by larger companies. There will be a consultation on the detail but the Government has stated that it … Continue reading Support for innovative industries
In line with the Chancellor’s stated aim to make the UK tax system the “most competitive in the world” the rate of corporation tax will be cut to 24% from 1 April 2012. It will be cut by a further 1% for each of the next two years to 22% from 1 April 2014.