Combating avoidance
Our prediction
No Budget would be complete without some measures to combat avoidance; this year will be no different.
It is expected that matters to be addressed will concentrate (or not) on:
Change of ownership of companies: unused capital allowances
The ability to access losses, unrelieved management expenses and charges has been severely curtailed over the years. An announcement was made on 21 July 2009 that measures would be enacted preventing the transfer of unused capital allowances in particular circumstances.
Corporation Tax Manufactured Payments
Special rules are required to deal with payments made where securities are lent and similar transactions. Recent litigation has highlighted the need for the legislation to deal with particular arrangements to avoid tax avoidance. Draft legislation has been published to put beyond doubt that where such amounts are received in the course of a sale and repurchase transaction (repo), those payments must be taken into account for tax to the extent they are taken into account in accordance with generally accepted accounting practice (GAAP).