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.
Next
- National Insurance Contributions |
