UK: UK Corporate Tax Reform Update - September 2011

While the UK Government's blue-print for corporation tax reform was put forward in June 2010, key elements of the reform programme have become much clearer during the course of the Summer of 2011. The long awaited detailed and extensive consultation documents on the reform of the UK controlled foreign companies rules and the UK Patent Box have been published, alongside a consultation on changes to the UK debt cap rules and extensive guidance on the foreign branch tax exemption which was enacted in the Finance Act 2011.

Taken together, these initiatives mark the latest developments in the Government's aim "to create the most competitive corporation tax regime in the G20".1 The Government's priorities in the corporate tax reform programme are to broaden the UK tax base, lower corporate tax rates, and promote a more territorial approach to taxation while also creating a tax system which is stable, aligned with modern business practices and which avoids complexity where possible.

In this Clients & Friends Memorandum, we have drawn together both summaries and analysis of the four key elements of corporate tax reform during this summer: the consultation on the controlled foreign companies rules and the Patent Box, the proposed changes to the UK debt cap rules and the position which has been reached regarding the foreign branch exemption.

As the summer draws to a close, we can be confident of saying that the corporate tax reform programme has been advanced by each of these initiatives. However, we can be equally confident that much work remains to be done by the Government to ensure that changes announced can be translated into workable legislation which is both integrated across all the reformed areas of corporate taxation and which, taken as a whole, achieves the overall objective of increasing the competitiveness of the UK as an attractive jurisdiction for business.

Consultation on Controlled Foreign Companies Reform

On 30 June 2011, HM Treasury and HMRC published a consultation document (the "Consultation Document") setting out in detail their proposals for full reform of the UK controlled foreign companies ("CFC") rules.

Overview

The Consultation Document identifies the Government's aims for the revised CFC regime as being:

  • to target and impose a CFC tax charge on profits artificially diverted from the UK;
  • to exempt foreign profits where there is no artificial diversion of UK profits; and
  • to ensure that profits arising from genuine economic activities undertaken outside the UK are not subjected to UK corporation tax.

The Consultation Document is detailed, weighing in at 110 pages, including annexes which cover certain aspects of the reform in more detail. The key proposals of the Consultation Document through which the Government's aims are to be achieved include the following:

  • the CFC regime will continue to be entity based, but will impose a tax charge only on profits of a CFC which have been artificially diverted from the UK;
  • the focus of the regime is on CFCs which are perceived as being the greatest risk to the UK tax base. These are CFCs with significant monetary assets, with risks and profits which are not commensurate with their underlying activities, or which hold, or have interests in, certain intellectual property ("IP");
  • the introduction of a partial exemption for finance companies;
  • the introduction of a new approach in respect of CFCs holding intellectual property, in particular where the relevant circumstances relate to exploitation of IP transferred out of the UK in the last six years or where the profits arising from the IP are excessive in relation to the activities undertaken; and
  • the new regime will adopt a proportionate approach, ensuring that a CFC charge will only be imposed on a UK company on a proportion of profits in a CFC which have been treated as being artificially diverted from the UK.

A substantial amount of the new CFC regime rebrands the current rules in the existing CFC existing regime while refocusing on perceived areas of greatest risk to the UK tax base. Perhaps the most noteworthy example of rebranding is that the general purpose exemption in the proposed regime (which is available where no artificial diversion of profits from the UK has taken place) fulfils the same function as the motive test in the current CFC rules, but without a default presumption that profits would have arisen in the UK if the CFC had not existed. The provenance of the new regime will be helpful in assisting taxpayers and advisers through the network of rebranded exemptions and new provisions, with a non-statutory clearance procedure being available to provide certainty in cases of difficulty or particular uncertainty.

The proposed date for the introduction of the new CFC regime will be, at the earliest, for accounting periods beginning on or after Royal Assent to the Finance Bill 2012.

Identification of a CFC

A CFC will be defined as a foreign company resident outside the UK (whether in the EU or not), directly or indirectly controlled from the UK, which, as a consequence of its non-residence, pays less tax on its profits than it would if it were subject to UK tax. This lower effective level of tax is based on the actual tax paid in the CFC's jurisdiction of residence. The definition of a CFC therefore closely follows the definition in the current CFC regime. The Government has confirmed that it intends to maintain the lower level of tax threshold at 75% of the UK corporation tax that would have been suffered if the foreign company were resident in the UK. By 2014, this will mean that if foreign tax is greater than 17.25%, the CFC rules will not apply. The test will be based on the computation of UK taxable profits.

Consideration is to be given by the Government regarding how dual resident companies which are subject to CFC charges in multiple jurisdictions and treaty non-residents will be dealt with. The Consultation Document suggests a number of approaches to the definition of "control" for these purposes:

  • a principles-based test by reference to economic rights and actual control over the assets or income of a company;
  • an accounting test by reference to accounting consolidation; or
  • a mechanical test including the ability, either directly or indirectly, for the company's affairs to be conducted in accordance with a UK person's wishes (broadly being very similar to the current test).

The Consultation Document proposes that the basic rules for control will be supplemented by specific rules dealing with entities such as protected cell companies and JV vehicles, as well as provisions aiming to address current difficulties arising from the definition of "control" in practice.2

The key exemptions

A company will not constitute a CFC and will not therefore produce a UK tax charge on a UK participator in that company to the extent that the CFC qualifies for any one of the following exemptions:

  • low profits exemption;
  • excluded countries exemption;
  • temporary period exemption;
  • three territorial business exemptions;
  • finance company partial exemption;
  • banking exemption;
  • insurance exemption; and
  • general purpose exemption.

Very broadly, the exemptions are intended to exclude from the UK CFC regime those CFCs which pose a low risk to the UK Exchequer. The exemptions apply to the activities of the CFC, with any CFC charge applying to non-exempted activities.

Low profits exemption: The Consultation Document builds on the low profits exemption provision in Finance Act 2011 (which provides an interim exemption for a CFC with annual profits of up to £200,000 using an accounts based measure). The Consultation Document proposes retaining this exemption, or adopting a more flexible de minimis threshold. The suggestions are for either an upper profits threshold (suggested to be £500,000 with a maximum investment income component of £50,000 or 10% of total group income) or an upper profits threshold in line with the group's total group turnover (with a lower profits limit of £200,000 and an upper profits limit of £1 million).

Excluded countries exemption: As an equivalent to the "white list", this exemption would apply to CFCs located in jurisdictions with tax regimes that have broadly similar rates and tax bases to the UK. Certain requirements would govern eligibility for the exemption, including a local management condition. The exemption would be based on the CFC's jurisdiction of tax residence, although transparent entities such as US LLCs which do not have a jurisdiction of residence (and therefore do not qualify for the current exempt activities or excluded countries exemptions) will be eligible to qualify for the new excluded countries exemption. The Government has declined to introduce a general EU wide exemption.

Temporary period exemption: Following the amendments enacted in the Finance Act 2011, an exemption for up to three years will be available for potential CFCs which come under UK control as a result of third party acquisitions or group reorganisations. The exemption is more generous than the "period of grace" included in the pre-Finance Act 2011 motive test. The exemption will be subject to an anti-avoidance rule. The current approach of offering motive test exemptions in relation to certain acquisitions will not be carried forward into the new regime.

Three territorial business exemptions ("TBEs"): Three TBEs have been proposed which aim to exempt CFCs that undertake genuine commercial activities and do not pose a significant risk of artificial diversion of UK profits. The TBEs mirror the current CFC exempt activities test, but with mechanistic parameters and numerous conditions and requirements. These are identified in the Consultation Document as being:

  • profits rate safe harbour: this exemption would apply to a CFC which makes a low level of profits by reference to its cost base. The proposal advanced by the Government is for a single profit rate (as opposed to different sector specific rates), with a safe harbour of 10 per cent. of operating expenses (other than the cost of goods acquired for resale and related party business expenditure) being suggested. As dividends which are exempt from UK tax are excluded from the profits calculation, holding companies whose income consists mainly of dividends and whose investment income is no more than "merely incidental" should therefore be within this exemption;
  • manufacturing trades: The Consultation Document notes that most manufacturing activity poses little risk of artificial diversion of profits from the UK. CFCs which are not involved (to any substantial degree) in activities other than manufacturing will fall within this exemption. Once within the exemption, there would be no restriction on transactions with the UK and incidental amounts of investment income would also be permissible for the manufacturing CFC. Where the manufacturing CFC uses and exploits IP in its business, the Consultation Document permits the CFC to fall within the exemption where the IP is "local IP" and where the CFC does not act as an "IP hub". "Local IP" is further described as having being developed by the CFC's own staff, being developed by third parties to be integral to the CFC's trade or, where acquired, being broadly the IP which is necessary for the CFC to carry out the manufacturing activities it performs in its jurisdiction; and
  • a general exemption for commercial activities: this exemption covers (i) trading and certain business activities between a CFC and other foreign companies (whether connected or unconnected); (ii) trading and certain business activities between a CFC and UK persons (whether connected or unconnected) where there is no arrangement in place to artificially divert profit from the UK; and (iii) trading activities relating to the exploitation of foreign IP which does not pose a significant risk to the UK tax base. These exemptions share a common set of parameters, namely an establishment requirement and a local management condition. As with the other TBEs, incidental amounts of investment income would be exempted. The interaction between the general commercial TBE and investment income of a CFC is important. The Consultation Document mentions the proposal to permit around 20 per cent. of the CFC's business to consist of certain investment activities such as holding and managing shares and securities of non-group companies and some leasing activities. The rules for permitting merely incidental investment activity in a CFC falling within a TBE are also proposed in such a way as to avoid the creation of a "cliff-edge" or detailed rules to quantify the level of activity.

Each of these TBEs is expressed as being "mechanical" in nature and is subject to a "local management" condition requiring the CFC to be controlled and managed by sufficient staff of the necessary expertise and seniority. The CFC would need the capacity to evaluate investment proposals and to appoint, instruct and manage sub-contractors and consultants.

Incidental finance income arising from short term working capital needed for the business will also fall within the TBEs. Intra-group finance income in excess of this will be dealt with under the finance company rules (see below). As the CFC charge will now be calculated on a mixed entity/income stream approach on a proportionate basis, it will no longer be possible to "swamp" finance income with trading income. A number of options are considered in the Consultation Document for defining incidental finance income for the TBEs and the regime generally. These included a simple fixed percentage of the CFC's profits using a measure such as EBITDA, a simple percentage of the CFC's gross income and a more flexible definition (at the risk of added complexity) reflecting the particular facts of the CFC's business and recognising that some types of business may have greater short term working capital needs than others (and therefore produce more incidental finance income).

Finance company partial exemption: As already revealed in the November 2010 consultation document, the CFC regime will include a partial exemption for finance companies ("FCPE"). This is designed to apply to overseas intra-group finance income that represents the structural surplus cash reinvested within the group to the extent it exceeds amounts incidental to the CFC's business. The assumption embedded within the FCPE is that most finance companies are wholly equity funded and, applying a deemed 1:3 debt-to-equity ratio, would give rise to a UK apportionment of 25 per cent. of the CFC's profits. This would lead to an effective UK corporation tax rate of 5.75 per cent. on profits from overseas intra-group finance income by the financial year 2014, which would be a quarter of the UK normal corporation tax rate.

The Consultation Document states that the Government's preferred position is for an apportionment approach focusing on the CFC's profits and losses by means of undertaking a UK chargeable profits calculation, although the interaction with the UK debt cap rules is currently unclear. An imputation approach, focusing on the balance sheet of the CFC, and deeming any excess equity of the CFC to be a loan from the UK, does not appear to be favoured by the Government. There is also a tantalising reference in the Consultation Document to the possibility of a full exemption for overseas finance companies, although no substantial details are given.

A number of additional aspects of the FCPE are explored in the Consultation Document. These include the requirement that a CFC will need to be established and managed in its territory of residence to fall within the FCPE, notwithstanding that HMRC acknowledges that such companies are unlikely to require significant numbers of employees. A number of options governing the precise form of the FCPE are considered, together with detailed examples. The Consultation Document proposes a simple design option for the FCPE, with three more complex alternatives. The simple option applies the FCPE to wholly equity-funded CFC's which only lend to other overseas group companies that are not themselves subject to the CFC apportionment rules. An amount of 25 per cent. of the finance CFC's profits would be apportioned to the UK under this simple option. However, many groups would not fit easily into the simple option, particularly groups which may feature intra-group finance to CFC's in respect of which a taxable apportionment is being deemed to a UK group member, hybrid-instruments or interest free loans. The other three options explained in the Consultation Document, focusing (respectively) on (i) the CFC's chargeable finance income; (ii) the CFC's chargeable finance profits; or (iii) an apportionment of chargeable finance profits are all explored with detailed illustrations but add complexity.

CFC's providing treasury management services, such as group cash pooling, are considered to be a low risk class of companies in the Consultation Document and the intention of the Government is for such companies to fall within the GPE (see below). Companies in which treasury management and finance/ structural lending are combined will only fall within the FCPE. Where a group wishes to obtain the full exemption under the GPE, it may be necessary to restructure the company to ensure that finance and treasury functions are conducted in separate companies. Similar issues arise in the context of "mixed activity companies" where trading activities are combined with financing operations such as the management of funds. The Government has received mixed responses in this area from the November 2010 consultation, and under the simplest definition of the FCPE the Government acknowledges that some restructuring may be required to ensure that financing activity of a more than merely incidental nature is carried on in a separate company in order to fall within the FCPE.

One of the most interesting sections of the Consultation Document addresses the areas which do not fall within the scope of the FCPE. The FCPE:

  • will not apply to non-incidental finance income from surplus cash deposits with third parties;
  • will not apply to non-incidental finance income from upstream loans by a CFC to UK connected parties unless the income arises in respect of short term loans in certain commercial situations, including where funding is provided to ameliorate insufficiencies of distributable reserves, or to comply with bank restrictions imposed by regulatory requirements or as part of a group's wholly commercial treasury management policy;
  • is unlikely to apply to overseas branches of UK companies owing to the difficulty in determining the amount of finance income attributable to the branch. Restructuring may be required for groups with overseas branches wishing to use the FCPE; and
  • will not be applicable to banking or insurance groups, owing to HMRC concerns that "monetary assets to different extents are intrinsic to their trade" and that separating monetary assets which support trading from assets supporting a capital structure is highly complex3.

It will be particularly interesting to see whether there is any relaxation to the Government's position in the Consultation Document by reference to the areas where the FCPE will not apply, particularly as these areas are ones where the general purpose exemption (or, currently, the motive test) is unlikely to apply.

Insurance exemption: Specific exemptions have been proposed for CFCs conducting insurance business. The insurance exemption is sector specific and effectively replaces the current modified variant of the CFC exempt activities test as applicable to insurance companies. The proposed insurance exemption would encompass genuine overseas insurance operations (including reinsurance) and would exempt foreign to foreign intra-group insurance activity (thereby removing the current limitation on foreign to foreign connected party insurance activity). The availability of the exemption is dependent on the CFC being part of an insurance group and being engaged in the business of carrying on or effecting contracts of insurance. Basic residence, establishment and local management requirements would also need to be satisfied in line with the requirements in the three territorial business exemptions described above. In addition, a requirement will be present that for the exemption to apply, an insurance CFC will need to have business consisting of 80 per cent. insurance activities4, which the Government anticipates should not be problematic given the regulatory restriction on noninsurance activities by regulated insurers.

Two options are proposed in the Consultation Document for the operation of the new exemption. The first option is for a simplified exemption for CFCs carrying on overseas insurance business which do not have a "significant connection" with the UK. The Consultation Document describes this as being an exemption where a CFC has less than 50 per cent. of commissions and premiums received under contracts of insurance (including third party and intra-group business) originating from the UK and is able to pass an appropriate capitalisation test. Under this option, CFCs which cannot meet this requirement must rely on the GPE or the excluded countries exemption.

The second option is a more flexible exemption route. The intention of the Government is stated to "remove lower risk genuine overseas insurance operations without needing to consider a capitalisation test". Where an insurance CFC can demonstrate that premium and commissions from UK (third party and intra-group) and connected parties are below a certain threshold, the exemption would be available. In the event that the connected party gross trading receipts are above that threshold (but below a ceiling threshold) an appropriate capitalisation test would need to be met for the exemption to be available. CFC's breaching the ceiling threshold would need to rely on the GPE or the excluded countries exemption.

To read the remainder of this document please click here.

Footnotes

1 "Corporate Tax Reform: Delivering a More Competitive System", HM Treasury, 29 November 2010, paragraph 1.2.

2 One example cited in the Consultation Document of these difficulties is the situation where UK-based creditor banks are at risk of being treated as controlling a foreign company though entitlement to assets on a winding up of a foreign debtor. Once the Government's commitment to address areas of uncertainty of this nature is taken into account, there are good arguments to resist any radical replacement of the well-understood current control test with new proposed approaches focusing on a "principles-based" identification or accounting definition of "control".

3 The same concerns militated in favour of the exclusion of regulated insurers and banks from the application for the worldwide debt cap rules in 2009.

4 An identical requirement is present in the other TBEs.

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