Budget 2011: a 'sticking plaster' approach to legislation?

Like jelly and ice cream at an old-fashioned children’s birthday party there are some things no good Budget should be without – anti-avoidance measures blocking ideas I wish I had thought of liberalisations that will make a real difference (and some that won’t) and changes to bits of the tax code that I had forgotten existed. This Budget is no exception. But imagine for a moment the Budget equivalent of a modern children’s party with professional entertainer and elaborate party bags. What would that contain?

For those of us who spend time advising those wanting to invest in the UK the sheer size and complexity of the rules dealing with interest deductibility make even the opening client conversation hard to navigate. Rules on distributions transfer pricing section 441 anti-arbitrage and worldwide debt cap to name but a few. We know why worldwide debt...