While most of the provisions in FB 2011 were subject to consultation following the release of draft legislation in December 2010, the Bill also contains measures that were announced for the first time in the 23 March Budget. These new measures include: increases in the rate of the Bank Levy and the income tax relief for EIS; the doubling of the lifetime limit for entrepreneurs’ relief; bringing forward the commencement date for the interim CFC provisions; modifications to the foreign branch exemption rules; and changes to the loan relationship derecognition provisions and group mismatch provisions. An amendment has also been proposed concerning elections for the company degrouping rules. Changes affecting disguised remuneration reflect comments made during the consultation process.
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