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Here you can access summary of the key current tax developments in Ireland, the UK and internationally as reported by Chartered Accountants Ireland

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Corporate Tax Reform Roadmap Published

Following on from the Chancellor's Autumn Statement in the House of Commons the Government has published details of its Corporate Tax Reform programme. The stated aim is to improve the UK's tax competitiveness.

The published document entitled ‘Corporate Tax Reform: Delivering a More Competitive System’ denotes how the Government intends to work with business to enhance UK tax competitiveness. Measures include the introduction of new Controlled Foreign Company (CFC) rules and a commitment to introduce a Patent Box.

Broken down into three parts, the document collects a series of reforms into a single programme. By doing so, the Government believes that this will allow a conjoined Government and business approach, to examining the interactions between the different elements, in a coherent and systematic manner.

Part 1 considers the reform plan as a whole and sets out how the Government will approach each element and includes the Government's:

  • Principles for corporate tax reform
  • Approach to corporate tax reform
  • Timetable for reform
  • Engagement strategy

Part 2 considers medium-term reform in two key areas, the Controlled Foreign Company (CFC) rules and the taxation of intellectual property and R&D tax credits. Here the Government intends to legislate resulting changes in Finance Bill 2012.

Part 2A sets out proposals to reform the UK's CFC rules on the key issues of monetary assets and intellectual property.

Part 2B sets out the role intellectual property plays in the Government's ambitions for the corporate tax system. It includes proposals to introduce a Patent Box; and a review of the support R&D tax credits provide for innovation, including the proposals of the Dyson Review.

Part 3 provides an update on reforms announced in the June Budget for inclusion in Finance Bill 2011. Part 3A sets out proposals for CFC interim improvements with Part 3B setting out proposals for reform of foreign branch taxation.

The Government also plans to establish a number of working groups to focus on detailed policy issues on CFCs (monetary assets, IP, insurance, banking and property), Patent Box and R&D tax credits.

In addition the Government has established the Business Forum on Tax and Competitiveness, chaired by the Exchequer Secretary, to consult with large businesses on the UK's tax competitiveness, including the long term aims of reform of the corporate tax system.

In short the key plans over the next five years look like this:-

Year 1

Autumn 2010

Publish paper on reforming CFC rules

Publish paper covering IP, the Patent Box and R&D tax credits

Publish further details on the CFC interim improvements and on chosen option for foreign branch reform

Year 2

Spring 2011

Introduce rate cuts in Small Profits Rate and the main rate to 27 per cent

Publish further details of new CFC rules for consultation

Publish further details of the Patent Box for consultation

Finance Bill 2011

Legislate for capital allowances reductions

Legislate CFC rules interim improvements and foreign branch reform

Autumn 2011

Publish draft legislation on (a) new CFC rules and (b) the Patent Box Y

Year 3

Spring 2012

Introduce further cut in main rate to 26 per cent and reductions to capital allowances

Finance Bill 2012

Legislate outcomes following consultation on (a) new CFC rules and (b) the Patent Box

Year 4

Spring 2013

Introduce further cut in main rate to 25 per cent and the Patent Box

Year 5

Spring 2014

Introduce further cut in main rate to 24 per cent

For details of the Chancellor's Autumn forecast statement go to: http://www.hm-treasury.gov.uk/press_65_10.htm.

The full text of the various publications in the Government's suite of Corporate Tax reforms is available at http://www.hm-treasury.gov.uk/corporate_tax_reform.htm