The 2017 Autumn Budget contained much that had already been announced. No mention is made of these measures unless there have been changes.
The Finance Bill 2017-18 is to be published on 1 December 2017.
The marriage allowance, transferring personal allowance between spouses, will be available in the case of deceased spouses, backdated 4 years.
Intangible fixed assets
Legislation will ensure licence arrangements between a company and a related party in respect of Intangible Fixed Assets are subject to the market value rule. The government will also legislate to ensure that realisations of a company’s intangible fixed asset, where consideration is wholly or partly something other than cash, will recognise the market value of that consideration.
Corporate indexation allowance
The indexation allowance on corporate Capital Gains for disposals on and after 1 January 2018 will be frozen. The allowance for subsequent disposals will be frozen at the amount that would be due based on the Retail Price Index for December 2017.
Research and development
The Finance Bill will increase the rate of the R&D expenditure credit from 11% to 12%, in order to support business investment in R&D.
Legislation will ensure that asset managers receiving carried interest pay capital gains tax on their full economic gain from 22 November 2017. The changes will remove the special treatment afforded to carried interest that arises in connection with disposals of assets before certain dates in 2015.
Royalties payable to non-residents
A consultation will be published on 1 December 2017 on the design of rules expanding the circumstances in which a royalty payment to persons not resident in the UK has a liability to Income Tax, with effect from April 2019.
Legislation will clarify partnership taxation in particular circumstances where the current rules for partnerships are seen as creating uncertainty, and will reduce the scope for non-compliant taxpayers to avoid or delay paying tax.
Venture Capital Schemes
Legislation will ensure the Venture Capital Schemes (the Enterprise Investment Scheme (EIS), Seed EIS and VCTs) are targeted at growth investments. Relief under the schemes will be focussed on companies where there is a real risk to the capital being invested, and will exclude companies and arrangements intended to provide ‘capital preservation’. HMRC will cease to provide advance assurances for investments that appear not to meet this condition.
It will also require all employees, and self-employed individuals, who have received a disguised remuneration loan to provide information to HMRC by 1 October 2019.
The VAT registration and deregistration thresholds will not be uprated for a period of two years. There will be no revisions to existing legislation and no new legal provisions will be introduced.
New anti-avoidance rules that relate to the taxation of income and gains accruing to offshore trusts will be introduced. This measure ensures that payments from an offshore trust intended for a UK resident individual do not escape tax when they are made via an overseas beneficiary or a remittance basis user.
This overview covers only a limited number of the new tax provisions. It should not be considered as advice or relied on when considering whether to take any action.