The Corporate Tax Roadmap: How To Achieve "Change" (By Not Changing Anything)

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The UK Government's new "Corporate Tax Roadmap" offers stability by retaining key corporate tax features but signals stricter international compliance measures. Multinationals gain reassurance in a competitive UK tax environment despite rising employer costs.

United Kingdom Tax

As part of a very busy Budget for tax reform, the UK Government has published a new "Corporate Tax Roadmap" which sets out its plans for corporate tax over the next few years.

For all the noise around "change" (and there is plenty of change in other tax policy areas), what the roadmap is trying to do is offer certainty for business through the Government promising not to change the UK's approach to corporate tax.

In particular, multinationals investing in the UK can take reassurance that the Government says it has no plans to change some of the key features of the (broadly attractive) UK corporate tax landscape.

In particular, the Government says it will retain:

the main features of the UK's holding company regime (substantial shareholding exemption, dividend exemption and optional branch exemption);
tax relief for interest costs;
the 25% headline tax rate (as a cap - in theory it might go down);
full expensing for capital investment;
the patent box and R&D reliefs; and
adherence to the OECD rules on Pillar 2.

That is the upside. Looking at developments that businesses may feel less enthusiastic about, these mainly relate to international tax compliance and measures to protect the UK tax base. There are hints in the roadmap that transfer pricing compliance and international reporting obligations are going to become more onerous as HMRC looks to ensure it is collecting as much tax as possible from profits attributable to UK activities.

Overall, this is a package that should reassure multinationals that the UK remains a competitive place to do business from a corporate tax perspective. Of course, that is not the complete picture given the wider context of this Budget - with the increase in employer national insurance contributions to 15% on remuneration of UK employees (introduced to raise additional tax revenue) representing an additional cost for businesses.

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