Corporates

Corporation Tax Rates

The Chancellor announced that there would be no change to the plan revealed in Budget 2016 that the Corporation Tax main rate will remain at 19% for the years beginning 1 April 2018 and 2019 having fallen from 20% at 1 April this year.    

The Government had also announced in the previous budget that the Corporation Tax main rate will be further reduced to 17% from 1 April 2020.    

The above changes clearly benefit corporations and family businesses of all sizes, with the cut in Corporation Tax forming part of the Government’s stated aim of making the UK an attractive place to do business. 

Indexation Allowance

The indexation allowance which aims to negate the effects of inflation on corporate capital gains is to be frozen from 1 January 2018.  The effect of this is that no relief will be available for inflation accruing after this date for companies selling chargeable assets.  Relief from the date of acquisition through to 1 January 2018 will continue to be available for disposals after this date.

The indexation allowance freeze brings the corporate gains rules in line with individuals and trusts, both of whom do not currently benefit from a relief linked to inflation.   

Tackling avoidance

The recent release of the “Panama Papers”, leaking details of offshore arrangements undertaken by wealthy individuals and companies intended to shelter assets from the UK tax net and/or avoid tax on income, led to criticism from the opposition that the Government was soft on tax avoidance. 
 
The Chancellor responded today, firstly by outlining in great detail the avoidance measures he and his predecessor had introduced since 2010, and secondly by announcing new anti avoidance legislation.  These latter measures included, but were not limited to, the following:

 
Withholding tax on royalties

With effect from April 2019 withholding taxes will apply to royalty payments made to low tax jurisdictions in relation to sales to UK customers.  In the past multi national corporates such as Apple, Amazon & Google have sought to reduce their tax exposure on UK profits by making royalty payments to group companies set up in low tax regimes.

 
Extending offshore time limits

Following a consultation period in Spring 2018 the Government intends to extend the time period during which they can recover taxes arising from non deliberate offshore non compliance from four years to twelve years.

  
Requirement to notify HMRC of offshore structures

Following consultation the Government will seek to introduce a requirement for designers of offshore structures which could be used to avoid UK taxes to notify HMRC of the structures and their clients who are using them.
 

NIC and Employment Allowance

To combat some employers abusing the Employment Allowance, in order to avoid paying the correct amount of NICs often by using offshore arrangements, HMRC are to require upfront security from

employers with a history of avoiding paying NICs in this way.

 
Disguised remuneration

The Government intends to tackle disguised remuneration avoidance schemes used by close companies (generally those with five or fewer shareholders) by introducing a close companies’ gateway to ensure liabilities from the new loan charge are collected from the appropriate person.

 
Double Taxation Relief

With immediate effect a restriction will be introduced to the relief for foreign tax incurred by an overseas branch of a company, to ensure the company does not get tax relief twice for the same loss.
 
To further bolster their attempts to target tax avoiders the Government is to invest a further £155 million in additional resources and new technology for HMRC, which they forecast will help bring in £2.3 billion of additional tax revenues.  This will assist and enable HMRC to:

  • tackle the hidden economy through new technology
  • further tackle those who are engaging in marketed tax avoidance schemes
  • tackle the enablers of tax fraud and hold intermediaries accountable for the services they provide using the Corporate Criminal Offence
  • tackle non-compliance among mid-size businesses and wealthy individuals
  • recover greater amounts of tax debt through a new taskforce to specifically tackle tax debts more than 9 months old

Using technology to build an economy fit for the future

The chancellor wants to leave future generations an economy fit for purpose.  This will be driven by technological innovation and his plans aim to see the UK becoming a world leader in new and emerging technologies.  Some of the key actions to achieve this are supporting connectivity between city regions, a further £2.3 billion support in R&D and unlocking £20 billion of patient capital so innovative high-growth firms can achieve their full potential.  Interestingly this is being combined with ambitions to lead the world in developing standards and ethics for data and AI whilst creating the most advanced framework for driverless cars in the world.  There are also plans to ensure the work force is fit for purpose to achieve these aims so that young people and people who want to retrain can learn the skills it takes to be innovators of the future.

 

The government is increasing the R&D Expenditure Credit to 12% with effect on or after 1 January 2018 in line with the governments ambition to raise the level of investment in R&D to 2.4% of GDP.  This will not only affect large corporates, but our smaller clients who undertake subcontracted R&D or have received state aid towards their R&D projects.

VAT Registration Threshold

Following on from the recent Office for Tax Simplification report into the current VAT system there has been concern that HMRC would look to reduce the VAT registration threshold.

Philip Hammond did address this report during his speech but confirmed that the VAT registration threshold, rather than seeing the usual small increase, would be frozen for the next two years.

Following this two year period, the UK will be likely to have left the EU and at this point there would be more flexibility to introduce a smoothing mechanism to limit the impact of the current cliff edge system, which may in turn then see the threshold reduced.

At least for now though, the threshold has not been reduced keeping many small businesses outside of the VAT regime.

VAT & the Construction Sector

Following on from a consultation looking at options for tackling fraud in construction labour supply chains, a domestic reverse charge will be introduced to prevent VAT losses.  Such a system already exists in other sectors, such as telecommunications, and shifts the responsibility for paying the VAT along the supply chain. 

This is to be introduced from 1 October 2019, giving both businesses and the Government the opportunity to prepare for the change.  It will be interesting to see whether there will be any de-minimis limit introduced for this new requirement.

Import VAT

Under current EU rules, businesses benefit from postponed accounting for VAT when importing goods from the EU, allowing a significant cash flow advantage.  It is not yet clear whether this benefit will be retained following Brexit however the government has identified this as a potential issue and will be looking at options available to mitigate any adverse cash flow impacts for businesses, post Brexit.

VAT & Vouchers

A Government consultation will take place on plans to legislate in the Finance Bill 2018-19 to ensure that when customers pay with vouchers, businesses account for the same amount of VAT as when other means of payment are used.

This is a new development and it will be interesting to see what proposals are introduced in relation to this.

Online VAT Fraud

The Chancellor announced plans to introduce legislation to extend HMRC’s powers to hold online market places jointly and severally liable for any unpaid VAT of UK traders operating through their platform.  This is an extension of the existing legislation which only impacts on overseas traders and would appear to be a positive step in reducing VAT fraud.

VAT Refunds

The Chancellor announced good news for UK Combined Authorities and certain fire services in England and Wales, with them becoming eligible for VAT refunds.

Grants will also be provided to help accident rescue charities meet the cost of VAT, which would normally be irrecoverable.

Fuel Duty

Fuel duty has been frozen for the eight year in a row, with it being estimated that this will save the average driver £160 a year.

Our handy Tax Facts Pocket Guide provides you with the rates and figures you need to manage your personal and business finances.

Autumn Budget News

Budget Highlights for UK Manufacturing

Whilst the recent budget didn’t throw up any significant headline announcements for our Manufacturing Sector, there were various items outlined which should have a positive impact on the sector, including: Research & Development

Budget Review for Retail Sector

There are number of areas in the Autumn Budget that will impact on the retail sector.

Impact of the Budget for Family Businesses

It will come with little surprise that the second budget of 2017 failed to offer significant headline announcements, despite the rumour mill going in to overdrive during the past few days.

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