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Listed and large corporate businesses

Budget 2011 implications

Capital allowances – yet more changes in 2012

From April 2012 the period of time over which businesses will obtain tax relief for their capital expenditure will alter.

Corporation tax rates

The Chancellor announced a reduction in the corporate tax rates for both large and small companies.

Government to consult on anti-avoidance measures to prevent treaty shopping

Anti-avoidance provisions to be introduced in 2012 aim to remove relief or exemption from UK tax where, in the Government’s view, unfair advantage has been taken of the UK’s favourable tax treaty network. Draft provisions will be announced later this year with an invitation for representations on these provisions.

UK to attract multinationals through tax competition on group activities?

Further to previous announcements, the Coalition Government has confirmed it will seek to use competitive tax rates on particular activities of multinational groups to encourage them to remain tax resident in the UK (or to consider migrating to the UK).

Changes to the taxation of foreign branches of UK companies plus CFCs give greater opportunities for UK outbound investors

Proposals for the exemption of overseas trading branches of UK companies from UK tax have been confirmed, which will be of particular interest to the financial sector, together with companies which operate through branches in low tax jurisdictions. Likewise, interim changes to the controlled foreign company rules can only be helpful.

Income tax and national insurance merger announced

The Government has announced plans to consult on reforms to integrate the operation of income tax and national insurance contributions (NICs).

Changes to capital gains de-grouping charges will facilitate disposals and spin-outs

Proposals for changing the way in which capital gains de-grouping charges are taxed will benefit groups that wish to spin off a trade or division in to a separate company for sale to a third party. Where that company is sold after Royal Assent of Finance Act 2011, the de-grouping charge may now be exempt from tax.

Major Reforms Ahead to attract Multinationals

Sweeping reforms of the UK’s corporate tax system are being made to enhance the appeal of the UK as a place to do business. Interim improvements to the CFC regime are disappointingly complex but the overall move is in the right direction.

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