Anti-avoidance

The chancellor last week announced several anti-avoidance provisions relevant to large companies. Some of the measures arose as part of the OECD base erosion and profit shifting (BEPS) initiative. Key details are:

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  a restriction on the amount of loss relief available to banks;
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  the introduction of a diverted profits tax;
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  country by country reporting; and
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  a measure to address hybrid mismatches.

More general measures include proposals to strengthen the disclosure of tax avoidance schemes (DOTAS) regime; to establish a taskforce aimed at preventing avoiders from circumventing the rules; and to enable HMRC to publish summary information about notified tax avoidance schemes and their promoters.

Research and development relief

Three separate measures were unveiled in the autumn statement in respect of research and development (R&D):

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  the rate of the above the line credit will increase from 10% to 11%, …