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Double taxation relief for trade
receipts Legislation will clarify the amount of double taxation
relief that will be given when foreign tax is paid on income that is a trade
receipt for UK tax purposes or on other income that is computed in a similar
way for UK tax purposes. The changes will generally take effect from 16 March
2005 for companies and from 6 April 2005 for individuals.
Avoidance through
arbitrage From 16 March 2005, legislation will counter tax
avoidance using arbitrage schemes that involve hybrid entities or hybrid
instruments.
Double taxation relief anti
avoidance With effect from 16 March 2005, legislation will counter
arrangements designed to give rise to excessive double taxation relief
claims.
Corporate intangible
assets Changes to the legislation covering corporate intangible
assets, such as goodwill, will amend the related party rules and market value
rules from 16 March 2005. Payment entitlements under the single payment scheme
for farmers will not count as eligible replacement assets for the purposes of
capital gains rollover relief (or hold-over relief in the case of depreciating
assets) when acquired by companies. This provision will apply to acquisitions
of payment entitlement from 22 March 2005.
Financial avoidance
Eight avoidance schemes that have been disclosed to the Inland Revenue under
the disclosure rules introduced in Finance Act 2004 will be blocked by
legislation. They include schemes based on stripped corporate bonds and
corporately owned capital redemption bonds.
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| The summary has been
prepared very rapidly and may contain errors for which we cannot be held
responsible. The proposals are in any event subject to amendment before the
Finance Act is passed. Advice should be taken before any action. |