ANTI AVOIDANCE
The Chancellor closed with effect
from today two tax loopholes being exploited by multinational companies. The
first measure is in relation to Controlled Foreign Companies (CFCs) that have
used UK dividends to satisfy their Acceptable Distribution Policy (ADP). Dividends
that a CFC pays to the UK will no longer count towards satisfying the ADP if
they are paid out of UK dividends, which do not count toward computing the chargeable
profits of the CFC.
Secondly, the use of complex schemes
whereby multinational companies have secured tax advantages by draining value
from subsidiaries, via tax free dividend payments, and have then sold these
subsidiaries to offshore group members before onward sales to third parties
have been closed from today.
In the past there has been confusion
over the taxation treatment of reverse premiums i.e. inducements by landlords
to potential tenants. Sums payable under agreements made on or after Budget
day will be subject to tax in all cases.
The Chancellor said that the general
anti-avoidance rule (GAAR) for corporate direct taxes remained an option for
the future, but that the Government would not be proceeding with a GAAR in this
Budget.
ASSISTANCE FOR
SMALL COMPANIES AND BUSINESSES
The Chancellor announced four new
measures to assist small business, the most significant being a reduction in
the corporation tax burden on small and growing companies. A new 10 per cent
starting rate for corporation tax will take effect from 1 April 2000 and will
apply to companies with taxable profits of up to £10,000. For companies with
taxable profits between £10,000 and £50,000 there will be a scaled increase
up to the small companies rate, which will start at £50,000. The 10 per cent
rate will not apply to close investment holding companies.
Small employers can currently pay
their PAYE and NIC quarterly if the average monthly total is less than £600:
with effect from 6 April 1999 this limit is increased to £1,000. The Chancellor
also announced the launch of a new Small Business Service (SB S), which will
provide independent business advice, and help with statutory compliance matters
including a new payroll service, to make it easier for employers to comply with
PAYE and NIC regulations. The SBS will be run as a joint venture with Customs
and Excise and will also promote the use of IT by small businesses including
electronic filing of statutory returns, which will attract a discount. Full
details are to be announced.
A new tax credit on research and
development by small and medium sized enterprises will be introduced in 2000:
no details are available at present.

