HM Treasury and HMRC published slides on the current status of their corporate tax reform consultation on 21 January 2011. (Free access.)
On 21 January 2011, HM Treasury and HMRC published slides detailing the current status of the corporate tax reform consultation (see Legal update, Corporate tax reform: CFCs, IP tax and foreign branch profits (full update) (www.practicallaw.com/1-504-1151)). This follows open events held on 13 December 2010 and 11 January 2011.
The slides do not contain any new substantive information except that:
Any reforms to the R&D rules (see Legal update, Research and development and IP tax consultation (corporate tax reform): R&D tax credits (www.practicallaw.com/5-504-0814)) are intended to be legislated as part of the Finance Act 2012.
It is still proposed that the CFC interim improvements (see Legal update, CFC interim improvements proposals (corporate tax reform) (www.practicallaw.com/6-504-0663)) will have effect for accounting periods starting on or after 1 April 2011, although this is subject to consultation and ministerial approval (the latter was not previously mentioned). At the open day on 11 January 2011, HM Treasury commented that it anticipates that the foreign profits rules (see Legal update, Foreign branch exemption detailed proposals (corporate tax reform) (www.practicallaw.com/3-504-0711)) may have effect from 1 January 2012, but the slides are silent on this.
The slides set out a helpful timetable for reform, with the next stage including the publication of further details of the new CFC rules and the patent box (see Legal updates, Full CFC reform proposals (corporate tax reform) (www.practicallaw.com/2-504-1179) and Research and development and IP tax consultation (corporate tax reform): Patent box (www.practicallaw.com/5-504-0814)) for consultation in spring 2011.