Tax law rewrite
HMRC continue the Tax Law Rewrite project with the following consultations relating to all aspects of corporation tax. Stakeholders – which means the smallest local accountancy firm as much as the big partnerships – are invited to contribute their views on the draft clauses by the stated dates:
l Loan relationships, derivative contracts and intangible fixed assets; provisions affected by the European Mergers Directive (Paper CC/SC (08) 27) – comments invited by 19 September 2008
l Intellectual property (Paper CC/SC (08) 26) – comments invited by 19 September 2008
l Relationships treated as loan relationships: open-ended investment companies, unit trusts and offshore funds (Paper CC/SC (08) 25) – comments invited by 19 September 2008
l Transfer pricing and advance pricing agreement provisions (Paper CC/SC (08) 24)- comments invited by 19 September 2008
l Oil Tax (Paper CC/SC (08) 35) – comments invited by 31 October 2008
l Distributions (Paper CC/SC (08) 23)- comments invited by 19 September 2008
l Changes in company ownership and recovery of corporation tax (Paper CC/SC (08) 22) – comments invited by 19 September 2008
l Manufactured payments and repos (Paper CC/SC (08) 20) – comments invited by 29 August 2008
l Use of different accounting practices within a group of companies (Paper CC/SC (08) 19) – comments invited by 29 August 2008
l Surrender of tax refunds within groups (Paper CC/SC (08) 18) – comments invited by 29 August 2008
Earlier consultations for which the comments are now closed include the following:
l UK representatives of non-UK residents (Paper CC/SC (08) 12)
l UK Real Estate Investment Trusts (REITs) (Paper CC/SC (08) 15)
l Charges on income (Paper SC/CC (08) 14)
l Permanent establishments and UK representatives (Paper CC/SC (08) 10)
l Distributions (Paper CC/SC (08) 11)
l Community amateur sports clubs (CASCs) (Paper CC/SC (08) 06)
Earlier consultations for which response documents have now been published by HMRC include the following:
l Tax arbitrage (Paper CC/SC (08) 01)
l Small companies relief (Paper CC/SC (08) 03)
l Partnership losses (Paper CC/SC (08) 02)
l Relief against income for losses on the disposal of shares (Paper CC/SC (08) 04)
l Charitable companies (Paper CC/SC (07) 43)
l Loss relief (Paper CC/SC (07) 38)
l Miscellaneous rules (Paper CC/SC (07) 37)
l Community investment tax relief (Paper CC/SC (07) 42)
l Company reconstructions without change of ownership (Paper CC/SC (07) 40)
l Group relief (Paper CC/SC (07) 27)
l Transactions in land (Paper CC/SC (07) 29)
l Corporate Beneficiaries under trusts (Paper CC/SC (07) 30)
l Transactions in securities (Paper CC/SC (07) 28)
In addition to the above, the draft of the Corporation Tax Bill No 5 was published in February 2008 and consultation ended in May. A full response document is in preparation.