"Autumn", according to the late French philosopher
Albert Camus "is a second Spring when every leaf is a
The Autumn Statement is one of two statements H.M. Treasury has
to make in response to the independent economic and fiscal forecast
that the Office for Budget Responsibility provides every year.
Since the 1990s, it has become customary for Chancellors of the
Exchequer to combine their autumn response with tax and spending
announcements. The result is that we have become accustomed to a
second major fiscal event after the Budget each year.
The Chancellor, Philip Hammond, announced today "I am
abolishing the Autumn Statement". It is the Government's
intention, following the Spring 2017 Budget, to move the Budget to
autumn each year. From Spring 2018 the Spring Budget will be
replaced by the Spring Statement and Autumn Statement will be
replaced by the Autumn Budget.
And so what blew in with this year's autumn leaves?
The Government is still committed
post the EU referendum to cut the main rate of corporation tax from
20% to 17% by 2020.
To tackle tax avoidance, measures
against disguised remuneration tax schemes are to be extended to
their use by the self-employed.
The capital gains tax, income tax and
National Insurance contributions advantages of using Employee
Shareholder Status schemes will be removed for new agreements
entered into on or after 1 December 2016.
The Government's tax policy
consultation summaries (including the closed consultation on the
taxation of non-domiciles) and the draft Finance Bill legislation
will be published on 5 December 2016.
However we know the changes in this
area will be broadly in line with the proposals. Non-domiciled
individuals who have a non-UK resident trust set up before they
become deemed-domiciled in the UK will not be taxed with effect
from 6 April 2017 on the arising basis on income and gains realised
outside the UK and retained in the trust.
A technical change with effect from
Royal Assent Finance Bill 2017 will safeguard life insurance
policyholders from disproportionate tax charges under current
legislation by being given the right to apply to HMRC to have the
charges that arise in certain circumstances from part-surrenders
and part-assignments of their policies recalculated on a just and
Another technical change will confer
on the Government power to amend by regulations the list of assets
that life insurance policyholders can invest in without triggering
tax anti-avoidance rules for Personal Portfolio Bonds.
The annual charges for the Annual Tax
on Enveloped Dwellings (ATED) will rise in line with inflation for
the 2017 to 2018 chargeable period.
Foreign pensions and lump sums are to
be brought fully into tax for UK residents, to the same extent as
domestic ones, including updating the eligibility criteria for
foreign schemes to qualify as overseas pensions schemes for tax
The defence of having relied on
non-independent advice as taking 'reasonable care' when
considering penalties for any person or business that uses a tax
avoidance arrangement is to be removed.
At Budget 2017 the Government intends
to consult on bringing non-resident companies' UK income into
the corporation tax regime.
The Government also intends to
consult on a new legal requirement for intermediaries arranging
complex structures for clients holding money offshore to notify
HMRC of the structures and the related client lists.
The Government intends to introduce a
new legal requirement to correct a past failure to pay UK tax on
offshore interests within a defined period of time, with new
sanctions for those who fail to do so.
Originally published November 2016
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The government has been working to incorporate the changes required as a result of the OECD's work on BEPS Action 5: Harmful Tax Practices, which requires implementation of a Nexus approach to the Patent Box regime.
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