4
VENTURE CAPITAL SCHEMES
With effect from 30 November 2015, the provision of reserve energy generating capacity
and the generation of renewable energy bene"ting from other government support by
community energy organisations will no longer be qualifying activities under the Enterprise
Investment Scheme, Venture Capital Trusts or the Seed Enterprise Investment Scheme.
From 6 April 2016, the government will exclude all remaining energy generation from
the schemes.
RESTITUTION INTEREST
A special 45% rate of corporation tax on income is to be applied to restitution interest.
CORPORATION TAX
No changes were announced but changes may be introduced in Budget 2016.
If no changes are announced rates will be as follows:
Financial year to
31 March 2017 31 March 2016
Taxable pro"ts
All pro"ts
20%
20%
Loans to participators rate
25%
25%
Loans to participators, trustees of charitable trusts
Legislation will be introduced to ensure a tax charge is not applied to loans or advances
made by close companies to charity trustees for charitable purposes. The rules will apply to
qualifying loans or advances made on or after 25 November 2015.
Related party rules, partnerships and transfers of intangible assets
Revisions have been made to make it clear that transfers of intangible assets to a
partnership with companies as members will not circumvent the intangible "xed asset
commencement rules that would otherwise apply to those corporate members.
Capital allowances and leasing anti-avoidance
Legislation will be introduced in Finance Bill 2016 to tackle tax avoidance in relation to
both the manipulation of disposals to create excess capital allowances and the receipt
of consideration in a non-taxable form in return for agreeing to take over tax deductible
lease payments.
Firstly, the measure will prevent a person using an arti"cially low disposal value for capital
allowances purposes on the disposal of plant and machinery where tax advantage is one of
the main purposes of the arrangements which include that disposal.
Secondly, the measure will bring into tax as income, if not already so taxed, any
consideration received by a person, or connected person, for agreeing to take over
payments under a lease for which the person can claim tax deductions.
Northern Ireland rate of
corporation tax
The government remains committed to the
devolution of corporation tax powers to the
Northern Ireland Assembly, subject to the
Northern Ireland Executive demonstrating
that its "nances have been put on a
sustainable footing and that the range of
commitments entered into in the Stormont
House Agreement have been met.
The Northern Ireland parties have now
indicated that they wish to pursue the
implementation of a new Northern Ireland
rate of 12.5% in April 2018.
TAX EVASION AND
COMPLIANCE
A number of new measures will be
introduced by the government to tackle tax
evasion. The government will remove the
need to prove intent for the most serious
cases of failing to declare offshore income
and gains.
Civil penalties will be increased for
deliberate offshore tax evasion including
the introduction of a new penalty linked to
the value of the asset on which tax was
evaded and increased public naming of
tax evaders.
GENERAL TAX AVOIDANCE
The government will introduce several
new measures to reduce tax avoidance.
The measures include a 60% penalty of
the tax due which will be charged in all
cases successfully tackled by the general
anti-abuse rule, as well as tough measures
for those who persistently enter into tax
avoidance schemes and abuse reliefs, by
imposing restrictions on them accessing
certain tax reliefs for a period.