The government has published Finance Bill 2020, containing 105 clauses and 14 schedules, running to 176 pages. The Bill includes a number of measures for which legislation was published in draft on 11 July 2019 and at the Budget on 11 March 2020. The date for second reading has not yet been announced.
Measures for which legislation was published for the first time on 19 March include:
setting the rate of corporation tax at 19% for 2020 and 2021;
legislating the concessionary treatment applied since April 2019 to treat companies whose only corporation tax liability derives from a capital gain as ‘large’, as opposed to ‘very large’, allowing them to pay corporation tax 3 months and 14 days after the date the gain is realised, rather than immediately on the date of the gain;
increasing the rate of R&D expenditure credit from 12% to 13%;
reforming the intangibles regime to include intangible fixed assets acquired from related parties on or after 1 July 2020;
ensuring that non-UK resident companies carrying on a UK property business:
are taxed appropriately in respect of their loan relationships and derivative contracts for the transition from income tax to corporation tax, and
have a duty to notify their chargeability to corporation tax unless they have a reasonable expectation that tax deducted under the non-resident landlord scheme meets their tax liability;
confirming that the functions of an HMRC officer can be carried out in any way by HMRC, including by automated means such as a computer, to be treated as always having been in force;
clarifying that where an LLP is not carrying on a business with a view to profit, HMRC may treat a purported partnership return in the same way as it would treat a partnership return; and
allowing HMRC to make preparations for introduction of the plastic packaging tax before it is formally provided for in legislation.
The entrepreneurs’ relief legislation published at the Budget on 11 March has been revised to include anti-forestalling measures in relation to reorganisations as well as to share exchanges, and to rename the relief to ‘business asset disposal relief’ with effect from 6 April 2020.
Alongside the Bill, the government also published six consultations:
taxation impacts arising from the withdrawal of LIBOR;
second consultation on preventing abuse of the R&D tax relief for SMEs;
notification of uncertain tax treatment by large businesses;
hybrid mismatch rules;
tackling construction industry scheme abuse; and
call for evidence on raising standards in the tax advice market.
The government has published Finance Bill 2020, containing 105 clauses and 14 schedules, running to 176 pages. The Bill includes a number of measures for which legislation was published in draft on 11 July 2019 and at the Budget on 11 March 2020. The date for second reading has not yet been announced.
Measures for which legislation was published for the first time on 19 March include:
setting the rate of corporation tax at 19% for 2020 and 2021;
legislating the concessionary treatment applied since April 2019 to treat companies whose only corporation tax liability derives from a capital gain as ‘large’, as opposed to ‘very large’, allowing them to pay corporation tax 3 months and 14 days after the date the gain is realised, rather than immediately on the date of the gain;
increasing the rate of R&D expenditure credit from 12% to 13%;
reforming the intangibles regime to include intangible fixed assets acquired from related parties on or after 1 July 2020;
ensuring that non-UK resident companies carrying on a UK property business:
are taxed appropriately in respect of their loan relationships and derivative contracts for the transition from income tax to corporation tax, and
have a duty to notify their chargeability to corporation tax unless they have a reasonable expectation that tax deducted under the non-resident landlord scheme meets their tax liability;
confirming that the functions of an HMRC officer can be carried out in any way by HMRC, including by automated means such as a computer, to be treated as always having been in force;
clarifying that where an LLP is not carrying on a business with a view to profit, HMRC may treat a purported partnership return in the same way as it would treat a partnership return; and
allowing HMRC to make preparations for introduction of the plastic packaging tax before it is formally provided for in legislation.
The entrepreneurs’ relief legislation published at the Budget on 11 March has been revised to include anti-forestalling measures in relation to reorganisations as well as to share exchanges, and to rename the relief to ‘business asset disposal relief’ with effect from 6 April 2020.
Alongside the Bill, the government also published six consultations:
taxation impacts arising from the withdrawal of LIBOR;
second consultation on preventing abuse of the R&D tax relief for SMEs;
notification of uncertain tax treatment by large businesses;
hybrid mismatch rules;
tackling construction industry scheme abuse; and
call for evidence on raising standards in the tax advice market.
