The Budget 2008
Wednesday 12 March
You can download the Budget Summary in PDF format
here.
Introduction
Alistair
Darling presented his first Budget on Wednesday 12 March 2008.
After the
Northern Rock saga and the changes of mind on the ‘simplification’ of capital
gains tax, will it be his last?
On the
economy, the Chancellor stated that there will be no recession although he
conceded that growth up to 2010 will be less than previously forecast.
Borrowing will go up as a result.
Our summary
focuses on the direct and indirect tax measures which are buried in the Treasury
and HMRC press releases.
We
concentrate on the issues likely to affect you, your family and your business.
To help you decipher what was said we have included our own comments.
If you have
any questions please do not hesitate to contact us for advice.
Main Budget Proposals
- Plans to
stop the tax savings available to businesses by ‘income shifting’ are
delayed for one year
- Further
details on the changes to the capital allowances regime including the
taxation of company cars
- Improvements
to the Enterprise Management Incentive scheme
- Annual
charge on non-domiciles still to be introduced but some relaxations made
to the original proposals
- Income
tax relief extended for the Enterprise Investment Scheme
Previous Announcements
Many of the
changes detailed in this summary have been the subject of earlier
announcements. Here is a reminder of some of the more important ones:
- Reduction
in the basic rate of income tax and significant increases in national
insurance
- Increase
in the investment limits for ISAs
- The
abolition of taper relief and indexation allowance for capital gains tax
(CGT)
- The
introduction of a flat rate of CGT for individuals of 18% and a new
Entrepreneurs’ Relief
- A
significant change in inheritance tax relief for married couples and civil
partners
The Budget
proposals may be subject to amendment in the Finance Act. You should contact us
before taking any action as a result of the contents of this summary.
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Personal Tax
Tax Rates
As
previously announced the government proposes to radically change the tax rates
for 2008/09 onwards when the 22% basic rate of tax will be reduced to 20%. The
higher rate of tax will continue at 40%.
The current
starting rate will be abolished and replaced with a new 10% starting rate for
savings income. Where an individual’s non savings income (broadly earnings,
pensions, trading profits and property income) exceeds the new starting rate
limit, then the starting rate will be unavailable. There are no changes to the
tax rates applicable to dividends.
However the
rate of tax applicable to capital gains will change significantly to a flat
rate of 18% for 2008/09 (see Capital Taxes section).
Allowances
The 2008/09
personal allowances were announced in October 2007. The personal allowance for
the under 65s is increased in line with inflation to £5,435. Age related
allowances have been raised significantly to £9,030 for people aged between 65
and 74 and to £9,180 for those aged 75 and over.
Tax Credits
There are
two types of Tax Credits; Working Tax Credit and Child Tax Credit (CTC). The
CTC is potentially available to families who have responsibility for one or
more child. There are several elements to the credit but broadly the maximum is
an annual amount for 2008/09 of £2,085 per child together with a family element
(generally one per family) of £545 per annum. The amount per child has been
increased but the family element has been frozen since the introduction of the
credit.
Other
changes from April 2008 are:
- the
income threshold for Working Tax Credit will increase to £6,420 (currently
£5,220)
- a higher
rate of taper will apply for those in the fast taper band (up from 37% to
39%).
Individual Savings Accounts (ISAs)
Over the
last year the government has finalised the changes to ISAs which will be
introduced from 6 April 2008.
- The
annual ISA investment allowance will be raised to £7,200. Up to £3,600 of
that allowance can be saved in cash with one provider. The remainder of
the £7,200 can be invested in stocks and shares with either the same or a
different provider.
- ISA
savers will be able to invest in two separate ISAs in each tax year; a cash
ISA and a stocks and shares ISA. Mini and maxi ISAs will no longer exist.
- Mini cash
ISAs, TESSA-only ISAs and the cash component of a maxi ISA will
automatically become cash ISAs.
- Mini
stocks and shares ISAs and the stocks and shares component of a maxi ISA
will automatically become stocks and shares ISAs.
- All
Personal Equity Plans (PEPs) will automatically become stocks and shares
ISAs.
- ISA
savers will be able to transfer money saved in their cash ISA to their
stocks and shares ISA.
Foreign Dividends
The
government proposes to introduce amendments to the system of taxation for
individuals who own foreign shares. From 6 April 2008 individuals in receipt of
foreign dividends will be entitled to a non-repayable tax credit of one ninth
of the distribution. The legislation will apply to individuals who own less
than a 10% shareholding in the company.
From 2009,
individuals with shareholdings in excess of a 10% shareholding will also be
eligible for the non-repayable tax credit. The tax credit will not be available
where the source country does not levy a tax on corporate profits and
anti-avoidance measures will be introduced to ensure these new rules are not
subject to abuse.
Residence and Domicile
The
government will implement a package of reforms announced in the 2007 Pre-Budget
Report subject to certain changes. The measures will take effect from 6 April
2008.
The main
proposal is that UK residents who are non-domiciled or not ordinarily resident,
who wish to continue to be taxed on a ‘remittance basis’ rather than on their
worldwide income and gains, will have to pay an annual tax charge of £30,000 on
unremitted income and gains. Those with unremitted foreign income and gains of
less than £2,000 will however be exempt from this charge.
The charge
will apply if an individual has been resident in the UK for at least seven out
of the previous ten tax years. Individuals will be able to decide each tax year
whether to pay the charge and be taxed on the remittance basis or be assessed
on their worldwide income and gains.
Key changes
include:
- users of
the remittance basis will lose their automatic entitlement to certain
allowances, such as the personal allowance and the capital gains annual
exemption (unless the £2,000 de minimis applies)
- children
will not pay the £30,000 charge
- the
£30,000 charge should be creditable against foreign tax
- art works
brought into the UK for public display or for repair and restoration will
face no new tax charges
- income
and gains in offshore trusts will only be taxed when they are remitted to
the UK, even if these come from UK assets
- changes
will be made to the current rules on remittances to restrict the ability
of individuals to sidestep UK tax on income and gains where HMRC believe
it is due.
In
addition, from 6 April 2008, when determining if an individual is resident in
the UK, any day where the individual is present in the UK at midnight will be counted as a day of presence in the UK for residence test purposes. There
will be an exemption for passengers who are temporarily in the UK whilst in transit between two places outside the UK.
Enterprise Investment Scheme (EIS)
Individuals
can claim income tax relief of 20% on qualifying EIS investments. The current
annual limit on investment is £400,000 and this limit will be increased to
£500,000 subject to State Aid approval.
The EIS,
Corporate Venturing Scheme and Venture Capital Trust schemes are intended to
support investment in smaller higher risk trading companies. Most trades
qualify under the schemes but not those that consist to a substantial extent of
excluded activities. The activities of shipbuilding, coal and steel production
will be added to these exclusions from 6 April 2008.
Offshore Funds
The
government will simplify the rules for offshore funds. In order to retain the
favourable tax treatment for investors disposing of an interest in the fund, an
offshore fund will no longer have to make a distribution of at least 85% of its
income. It will instead be able to ‘report’ income to investors who will then
be subject to tax on that reportable income.
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Corporate and Business Tax
Corporation Tax Rates
The main
rate of corporation tax which applies to companies with profits of more than
£1.5 million falls to 28% from 30% from 1 April 2008 and that rate will be
maintained in 2009. The small companies corporation tax rate which applies to
companies with up to £300,000 of profits will increase from 20% to 21% from 1
April 2008. The intention is to increase this rate to 22% in 2009.
The
effective marginal corporation tax rate for profits between £300,000 and £1.5
million is 29.75% from 1 April 2008.
Simplification of the Associated Company Rules
The profits
limits referred to above may need to be shared between companies if the
companies are ‘associated’. Companies are associated if they are under common
shareholder control, for example where the same individual has more than 50% of
the ordinary share capital of each of the companies. However an individual may
be regarded as having control of two companies because shares owned by other
persons are deemed to be owned by the individual. This is known as the
‘attribution concept’.
From 1
April 2008, shares held by business partners will not be attributed to a person
unless a tax planning arrangement has been put in place in order to pay less
corporation tax than would otherwise be due.
Capital Allowances
Major
changes will be implemented to the capital allowances system from 2008/09. The
details for plant and machinery are:
- a new
Annual Investment Allowance (AIA) for the first £50,000 spent on plant and
machinery. This gives a 100% write-off against profits. The AIA
complements and does not replace any of the existing 100% first year
allowance schemes
- writing
down allowances for plant and machinery in the main ‘pool’ will be cut
from 25% to 20%
- a new
writing down allowance for ‘integral features’ in a building will be 10%
- writing
down allowances for long life assets will be increased from 6% to 10%
- the 10%
allowances will be given by combining integral features and long life
assets into a ‘special rate pool’
- the
special rate of 10% for integral features will include certain replacement
expenditure where this might otherwise have qualified as a revenue
deduction
- where
companies have a loss after claiming 100% first year allowances on green
technologies they will be able to reclaim a tax credit from HMRC.
Small Plant and Machinery Pools
Writing
down allowances at the rates summarised above are computed on the ‘pool’ of
unrelieved expenditure. When calculating writing down allowances there is no de
minimis rule so, for example, businesses with £1,000 of unrelieved expenditure
and no new expenditure or disposal receipts would have to carry on calculating
the annual writing down allowance for many years. Businesses will be able to
claim a writing down allowance of up to £1,000 in the case of each pool, once
the unrelieved expenditure in either the main rate pool or the special rate
pool is £1,000 or less.
This
measure has effect for chargeable periods beginning on or after 1 April 2008
for businesses within the charge to corporation tax and on or after 6 April
2008 for businesses within the charge to income tax.
100% Capital Allowances on Green Technologies
Two schemes
exist that give 100% first year allowances for expenditure on certain
energy-saving and water technologies. Following the annual review of the
qualifying technologies, the schemes will be revised to include one new
technology: waste water recovery and reuse systems. The Energy Technology
Criteria List will be revised to include four additional sub-technologies:
compressed air master controllers; compressed air flow controllers; heat pump
dehumidifiers and white LED lighting.
The 100%
first year allowance for expenditure incurred on natural gas and hydrogen
refuelling equipment due to end on 31 March 2008 will be extended for an
additional five years to 31 March 2013.
Taxation of Business Travel
With effect
from 1 April 2009 for corporation tax purposes (6 April 2009 for income tax)
the capital allowance treatment of all cars will be reformed.
- Expenditure
on cars with CO2 emissions above 160gm/km will
attract 10% writing down allowances.
- Expenditure
on cars with CO2 emissions of 160gm/km or below
will attract 20% writing down allowances.
- Subject
to State Aid approval, cars leased to those in receipt of certain
disability allowances will be placed in the 20% main pool, regardless of
their CO2 performance.
The rules
which disallow a proportion of car lease rental payments will be reformed in
line with the new capital allowances rules. The new disallowance will be 15% of
the relevant payments, applied to cars dealt with in the 10% special rate pool.
The 100%
first year allowances for the cleanest cars will be extended from 31 March 2008
to 31 March 2013 and the qualifying CO2 emissions threshold will be reduced to 110gm/km.
‘Income Shifting’
The
government intended that legislation would take effect from 6 April 2008 to
address ‘income shifting’. The government has reconsidered its position
following a period of consultation with business and now believes that a
further period of consultation will ensure that legislation in this area
provides clarity and certainty for businesses and their advisers.
The
government now intends to introduce legislation through Finance Bill 2009 and
will not enact legislation effective from 6 April 2008.
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Research and Development Tax Relief
Research
and development (R&D) tax relief gives enhanced tax relief to companies who
undertake qualifying R&D projects. The company must spend at least £10,000
on qualifying expenditure in one year. The proposed changes, subject to State
Aid approval, are:
- large
companies will be able to claim 130% relief, increased from 125%
- small and
medium sized companies will be able to claim 175% relief, increased from
150%.
Tax Simplification
The
government has introduced a rolling programme of tax simplification. Following
discussions with business and tax professionals, the government announced the
initial outcomes on the three tax simplification reviews launched in the 2007
Pre-Budget Report:
- VAT rules
and administration: consulting on ideas to simplify the operation of the
partial exemption regime and capital goods scheme
- anti-avoidance
legislation: repealing outdated anti-avoidance provisions on bond washing
and employment securities
- corporation
tax rules for related companies: simplifying the associated companies
rules (see above) and announcing a review looking at how to simplify
corporation tax calculations and returns for smaller companies.
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Employment Issues
National Insurance Contributions (NIC)
There is no
change in the rates of NIC. For 2008/09 the upper earnings limit, above which
employees continue to pay contributions of 1% on earnings, will be increased by
£100 per week. This gives an annual figure of £40,040.
The upper
profits limit for Class 4 national insurance for the self-employed will also be
increased in 2008/09 to £40,040.
In 2009/10
the upper earnings and profits limits will be aligned with the point at which
the higher rate of income tax becomes payable.
Company Cars and the Fuel Scale Charge
Where a
company car is provided for an employee’s private use, a taxable benefit arises
which is based on the list price of the car and its CO2 emissions. The percentages range from 15% to 35% for most
cars. There are discounts currently available for environmentally friendly cars
and from 6 April 2008 there will be:
- a 2%
discount for cars that have been manufactured to run on E85 fuel
- a new 10%
company car tax band for non-electric cars emitting no more than 120gm/km
of carbon dioxide. Environmentally friendly discounts do not apply to such
cars but the diesel supplement does.
If free
fuel is provided with a company car for private motoring then a fuel benefit
tax charge arises based on the percentage used for the car benefit and a
‘multiplier’, which is currently £14,400. For 2008/09 the figure will increase
to £16,900.
Tax Free Mileage Allowances
The
government has been consulting on changing the system and rates for tax free
mileage allowances where an employee uses their own car for business purposes.
It has been decided that the system will not change and the rates will be
maintained at current levels. The current rates are:
- business
mileage up to 10,000 miles – 40p
- business
mileage above 10,000 miles – 25p.
Enterprise Management Incentive (EMI)
EMIs are
tax and NIC advantaged share options available to small companies with gross
assets not exceeding £30 million, to help them recruit and retain employees.
Currently employees cannot hold qualifying EMI options, taking into account
Company Share Option Plan options also granted to them, with a total market
value of more than £100,000 at date of grant.
Regulations
will be made to increase the individual employee limit on grants of EMI
qualifying options from £100,000 to £120,000. The change to the individual EMI
option grant limit will have effect in respect of options granted on or after 6
April 2008.
To ensure
compliance with EU State Aid guidelines, legislation will be introduced in the
Finance Bill to make two changes:
- EMIs will
be limited to qualifying companies with fewer than 250 full time employees
- companies
involved in shipbuilding, coal and steel production will no longer qualify
for EMI.
Residence and Domicile: Changes for Employment Related Securities
Employment
related securities and securities options are shares and other securities, and
options over such shares or securities, which are acquired by an employee by
reason of their employment.
Employees
who are not resident and not ordinarily resident in the UK at the time employment related securities or options are acquired are not within the scope of all
of the charging provisions. Changes will be introduced in the Finance Bill to
bring such employees within all the charging provisions so that their
remuneration from employment related securities or options is subject to the
same rules as other employees.
Where such
employees are taxed on the remittance basis, the measure will provide
apportionment of the employment related securities income to ensure that the
proportion relating to overseas duties will only be subject to income tax when
it is remitted to the UK.
A similar
apportionment basis will be available to non-domiciled individuals where the
relevant income relates to a foreign employment where the duties are performed
wholly outside the UK.
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Capital Taxes
Capital Gains Tax (CGT) Reform
The
Chancellor surprised everyone with proposed major changes to the CGT regime
last October. The changes affect individuals and trustees, but not companies.
The Chancellor has confirmed that legislation will be introduced with effect
from 6 April 2008 to give effect to a new single rate of CGT at 18% but many
business owners will continue to have the potential benefit of a 10% rate.
An annual
exemption will remain in place and for 2008/09 this will be £9,600. The annual
exemption allows the first element of gains made in a given tax year to be
exempt from CGT.
For gains
arising on or after 6 April 2008 changes to the CGT regime include:
- the
withdrawal of taper relief
- the
withdrawal of indexation allowance
- the
introduction of Entrepreneurs’ Relief
- simplification
of the share identification rules.
Taper Relief
Taper
relief was introduced for disposals on or after 6 April 1998 and can reduce the
amount of the gain chargeable to CGT. The amount of relief available depends on
whether the asset is classed as a business or non-business asset and also on
the length of time an asset has been held since 1998.
For gains
arising on or after 6 April 2008 taper relief will no longer be available. The
chargeable gain will be liable to tax at 18%, after deducting allowable losses,
any other reliefs and the annual exemption.
Indexation Allowance
Indexation
allowance was, for individuals and trustees, the precursor to taper relief and
gave relief for the effect of inflation on the costs incurred on assets.
Indexation was frozen as at 5 April 1998. Currently where an asset was held at
6 April 1998 and is disposed of after that date, any gain on the disposal may
be eligible for indexation and taper relief.
For gains
arising on or after 6 April 2008 indexation allowance will no longer be
available.
Entrepreneurs’ Relief
In response
to business leaders voicing their objections to the abolition of taper relief,
the Chancellor has introduced a new Entrepreneurs’ Relief. The main effects of
this relief are:
- the first
£1m of gains qualifying for relief will be charged at an effective rate of
10%
- gains in
excess of £1m will be charged at 18%
- an
individual will be able to make more than one claim for relief, up to a
lifetime total of £1m of gains.
The new
relief is similar to Retirement Relief, which was phased out with the
introduction of taper relief, but the new rules are designed to be simpler:
- there
will be no minimum age limit
- relief
will be available where the relevant conditions are met for a period of
one year ending with the disposal / cessation.
The relief
will apply to net aggregate gains arising on the disposal of:
- the
whole, or part, of a trading business that is carried on by the
individual, either alone or in partnership
- assets
used in a business which has ceased
- shares in
a trading company, or holding company of a trading group, provided that
the individual owns at least 5% of the voting rights in the company and is
an officer or employee of the company
- assets
used in a partnership or by a company but owned by an individual if the
assets disposed of are ‘associated’ with a disposal of shares or an
interest in partnership assets. The individual must make the disposal as
part of the withdrawal of the individual from participation in the
partnership or the company
- certain
disposals by trustees of business assets and company shares where a
‘qualifying beneficiary’ has a qualifying interest in the business /
shares.
A trading
business includes professions but only includes a property business if it is a
‘furnished holiday lettings’ business.
A trading
company will have the same meaning as currently applies for taper relief.
Entrepreneurs’ Relief – Transitional Rules
A number of
individuals have made a gain prior to 6 April 2008 and have deferred the gain
until after 5 April 2008. Entrepreneurs’ Relief may be available when the gain
becomes chargeable if the sale of shares in a trading company or the sale of an
unincorporated business would have met the conditions for Entrepreneurs’ Relief
if the sale had taken place after 5 April 2008.
The
deferred gains eligible for relief are where:
- shares in
a trading company were disposed of in exchange for loan notes in another
company which are Qualifying Corporate Bonds (QCBs)
- the gains
made on shares in a trading company or on the disposal of an
unincorporated business were reinvested in Enterprise Investment Scheme
shares or Venture Capital Trust shares.
If an
individual had shares in a trading company which were disposed of in exchange
for loan notes in another company which are not QCBs, there may be
Entrepreneurs’ Relief on the disposal of the loan notes after 5 April 2008.
However the loan notes would need to be issued by a trading company in which
the individual owns at least 5% of the voting rights in that company and the
individual is an officer or employee of that company.
Simplification of the Share Identification Rules
The current
rules for the identification of shares and securities for CGT purposes require
a complex order of identification, which is dependent upon the dates when the
assets were acquired.
Due to the
changes to taper relief and indexation allowance, all shares of the same class
in the same company will be treated as forming a single asset from 6 April
2008, regardless of when they were originally acquired. However certain
anti-avoidance rules will remain.
Inheritance Tax (IHT) Threshold
As
previously announced the IHT nil rate band will rise from £300,000 to £312,000
in 2008 and £325,000 in 2009.
Transferable Nil Rate Band
Transfers
of property between spouses or civil partners are generally exempt from IHT.
This means that if an individual dies and leaves some or all of their property
to their spouse or civil partner, they may not have fully used their nil rate
band.
The new
rules allow any nil rate band unused on the first death to be used when the
surviving spouse or civil partner dies. The transfer of the unused nil rate
band from a deceased spouse or civil partner, irrespective of the date of
death, may be made to the estate of their surviving spouse or civil partner who
dies on or after 9 October 2007.
The amount
of the nil rate band available for transfer will be based on the proportion of
the nil rate band which was unused when the first spouse or civil partner died.
Interest in Possession Trusts
The IHT
rules for interest in possession trusts (IIP) changed in 2006 so that they
became subject to rules which previously only applied to discretionary trusts.
The key
effect of those changes is that an IHT charge arises to an individual on
creation of such trusts during lifetime and the trust is charged to IHT on
distributions and every 10th anniversary of the creation of the trust.
Previously the IIP trust was not charged to IHT but on the death of the
beneficiary it was included in their IHT chargeable estate.
The
implementation of the 2006 changes was delayed for a transitional period for IIP
trusts in existence before 22 March 2006 to enable trustees to reorganise such
trusts without incurring charges under the new rules. The deadline for this
transitional period has been extended to 5th October 2008.
It is also
confirmed that the ‘transitional serial interest’ provision will apply where
the holder of an interest in possession trust at 22 March 2006 becomes entitled
to a new interest within the transitional period.
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VAT
Thresholds
The VAT
registration limits increase with effect from 1 April 2008 as follows:
- the
threshold for compulsory registration is £67,000
- the
threshold for voluntary deregistration is £65,000.
Car Fuel Scale Charges
Where an
employee is provided with free fuel along with a company car, an income tax
benefit in kind arises based on the CO2 emissions of the car. In addition the employer has to pay a VAT car fuel scale
charge. Revised tables have been issued for use from the start of the next VAT
accounting period beginning on or after on 1 May 2008.
Reduced Rate for Smoking Cessation Products
A reduced
5% VAT rate for ‘over the counter’ sales of smoking cessation products was
introduced from 1 July 2007 for a period of one year. The government has
announced that the 5% reduced rate will continue to apply.
Smoking
cessation products dispensed on prescription continue to be zero rated.
Option to Tax Land and Buildings
The
government will simplify the rules relating to the option to tax land and
buildings. It will also make changes to enable taxpayers to revoke an option to
tax after 20 years. The earliest date an option to tax will be revocable will
be 1 August 2009.
The
government also proposes to make changes to improve the practical
administration of the option to tax.
Claims
The
government will introduce rules to enable eligible businesses to make claims
for over declared output VAT or under declared input VAT which accrued before
the introduction in 1996 and 1997 of the three year time limit for claims. Claims
will need to be made by 31 March 2009.
Errors
The error
correction regulations for VAT permit the inclusion of errors below £2,000 on
the next return submitted. Errors exceeding £2,000 have to be separately
notified to HMRC. The de minimis limit will be increased to the greater of
£10,000 or 1% of turnover, subject to an upper limit of £50,000. This measure
will take effect for accounting periods commencing on or after 1 July 2008. The
change also applies to other indirect taxes.
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Other Matters
Gift Aid: Transitional Relief
As
mentioned in the Personal Tax section, the basic rate of income tax will be cut
from 6 April 2008 to 20%.
Donations
to charity under Gift Aid are made under deduction of basic rate tax which the
charity is then able to reclaim. With a 22% basic rate, a cash donation of £100
grosses up to £128.20 in the hands of the charity. At a 20% basic rate, the
same donation will only gross up to £125 for the charity.
UK charities and Community Amateur
Sports Clubs (CASCs) that claim repayments of tax in respect of qualifying Gift
Aid donations, and charitable intermediaries making claims on their behalf,
will be entitled to a transitional relief to mitigate the effect of the change
in the basic rate.
A
transitional relief payment will be paid by HMRC to the charity, CASC, etc when
a claim for repayment of tax is made relating to qualifying Gift Aid donations
made in the tax years 2008/09 to 2010/11.
The
government also intends to implement a package of measures aimed at reducing
the administrative burden for charities in operating the Gift Aid scheme.
Review of HMRC Powers, Deterrents and Safeguards
In 2007
legislative provisions on a new penalty regime were introduced. Further
provisions will be implemented by HMRC covering:
- the power
to obtain information and documents
- the
production of documents
- restrictions
on powers to obtain information and documents
- offences
in relation to documents
- powers to
inspect businesses
HMRC also
want to extend the new penalty provisions introduced last year to cover all
taxes, not just the five main taxes that they administer. Most of these new
provisions will take effect for 2009/10 onwards.
Payment, Repayment and Debts
HMRC intend
to introduce new legislation to:
- enable
HMRC to introduce a credit card payment service from autumn 2008
- enable
HMRC, later this year, to set the repayments they must make to individuals
and businesses against amounts owed to them
- modernise
and align HMRC’s debt enforcement powers to collect unpaid sums by taking
control of goods in England and Wales or by taking action through the
civil courts.
This summary
is published for the information of clients. It provides only an overview of
the main proposals announced by the Chancellor of the Exchequer in his Budget
Statement, and no action should be taken without consulting the detailed
legislation or seeking professional advice. Therefore no responsibility for
loss occasioned by any person acting or refraining from action as a result of
the material contained in this summary can be accepted by the authors or the
firm.