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With the Chancellor’s speech still ringing in our ears, we bring together the most important features of the Summer Budget 2015 for corporate lawyers alongside expert analysis and industry comment.
Corporate tax overview
The corporation tax rate will be reduced from 20% to 19% in 2017, and to 18% in 2020. Draft legislation due this autumn will also introduce new quarterly payment dates for companies with annual taxable profits of £20m or more, or where a company is part of a group, this threshold will be divided by the number of companies in the group. Affected companies must pay corporation tax in the third, sixth, ninth and twelfth months of their accounting period starting on or after 1 April 2017.
TIIN—Corporation Tax—modernisation of the taxation of corporate debt and derivative contracts
The rules governing the taxation of corporate debt (known as loan relationships) and derivative contracts are updated by a new measure announced by the government at Summer Budget 2015. The measure affects companies which are subject to corporation tax, which issue or hold debt or which are party to derivative contracts.
TIIN: Controlled Foreign Companies—loss restriction
The government has announced a new measure which aims to stop losses and other surplus expenses from being set off against the controlled foreign companies (CFC) charge on the profits of CFCs. A CFC charge arises to a UK company in relation to profits from its CFCs which have been diverted from the UK. The measure applies to profits which arise on or after 8 July 2015.
TIIN—Corporation tax and income tax—Disposal of stock other than in trade, and corporate intangibles
The tax treatment of transfers between related or connected parties of trading stock and of intangible fixed assets is clarified. The measure will affect any businesses liable to corporation tax and income tax and will have effect for transfers of trading stock or intangible fixed assets made.
TIIN—Corporation tax—Restriction of relief for business goodwill
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