The taxation of ‘middleweight’ businesses is unduly complex and the time is ripe for reform in this area. Would it not be better to simply allow certain businesses to be treated as tax transparent and thereby entirely remove the incidence of corporation tax? Or perhaps such companies could instead choose to be taxed on a similar basis to UK REITs?
Since the coalition government was formed we have seen three emerging themes in company taxation. Firstly there has been an increasingly hostile reaction to what is more often than not wrongly perceived to be aggressive tax avoidance. It is understandable that the coalition government both anticipated and responded to the public zeitgeist by the proposed introduction of a general anti-abuse rule. Secondly the coalition government has rightly sought to...