‘It looks to me like the triumph of big business – or rather the triumph of the Treasury's view of what big businesses need and want.
Companies should pay a fair rate of tax and ‘move vigorously towards the path of transparency’, the Labour peer and former newspaper publisher Lord Hollick told tax experts earlier this month, as campaigners renewed calls for country by country reporting (CBCR) by multinationals and claimed that
A targeted anti-avoidance rule intended to counter arrangements to secure a tax advantage in the transition to a new regime for life insurance companies will take effect from 21 March 2012 ‘because there is a significant risk to tax revenue arising from the transition’.
New legislation will address income tax avoidance under the ‘chargeable event’ regime ‘by putting beyond doubt that gains liable to income tax are not reduced where there are certain untaxed gains earlier in the life of the policy or contract, or by the use of certain cluster policy arrangements’
Proposed amendments to CAA 2001 will ensure that rules for calculating the lessee’s disposal value at the end of a long funding lease ‘operate as intended so that the relief available by way of capital allowances does not exceed the net expenditure of the lessee not otherwise relieved’.
Finance Bill 2012 will amend the settlements legislation to close an avoidance scheme involving corporate settlors. The purpose of the changes is to confirm that ‘income arising under a settlement is treated as that of the settlor only where the settlor is an individual’.
The Finance Bill will amend the SDLT rules on a transfer of rights (or sub-sale) ‘so that the grant or assignment of an option cannot be a transfer of rights’.
Finance Bill 2012 will amend ITTOIA 2005 s 168 to deny an income tax or corporation tax deduction being given where a payment ‘arises from avoidance arrangements’.
Finance Bill 2012 will contain anti-forestalling legislation to ensure that changes announced in the Budget to the VAT liability of (a) supplies of self storage facilities and (b) supplies of services and materials in connection with approved alterations of protected buildings are ‘fully effectiv