Overview

Alistair Darling’s last budget before the General Election generated 71 press releases – and this on top of the 35 that accompanied the Pre-Budget Report in December. In this briefing Norton Rose’s corporate legal services team analyses the changes of most relevance to clients.

The measures covered in this report are divided into the following sections:

Financial Institutions and Large Companies

- One-off Bank Payroll Tax (BPT) on employee bonuses
- Sale of leasing companies: ring fence election
- Dividends paid out of capital reserves
Consortium relief
- Changes in accounting standards
- Amendments to the “worldwide debt cap” legislation
- Stamp duty and stamp duty reserve tax
- Risk transfer schemes (overhedging and underhedging transactions)
- Insurance premium tax – premium splitting
- VAT imposed on certain postal services
- Financial Services Compensation Scheme interventions in relation to insurance contracts

Energy Infrastructure and Land

- Stamp duty land tax
- Real Estate Investment Trusts (REITs)
- Increase in annual investment allowance
- Enhanced capital allowances
- Missing trader fraud – emissions allowances and other services
- VAT treatment of gas, heat and cooling (place of supply rules)
- Landfill tax
- Landfill communities fund
- Change in rates of climate change levy
- Cushion gas

Transport

- Proposed amendments to the UK VAT exemption for aircraft
- Air Passenger Duty
- Taxable benefit on zero-emission and low emission vehicles

Technology and Growing Companies

- Venture Capital Schemes
- Landline duty
- Games Tax Relief

Employees and Individuals

- Approved share arrangements
- Pensions

Tax Avoidance and Revenue Powers

- Proposed principles-based anti-avoidance rule
- Changes to transactions in securities anti-avoidance rules
- Tackling offshore tax evasion
- Disclosure of tax avoidance schemes
- Close companies: release of loans to participators
- Countering double tax relief avoidance

Tax Rates and Allowances


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