ey-global-tax-policy-outlook-for-2015

United Kingdom
2.9 Country position on OECD Base Erosion
and Prot Shifting (BEPS) Action Plan
•
arrangements. The new tax is intended to apply from 1 April
intended to apply to large multinational enterprises with
business activities in the UK who enter into “contrived”
contrived arrangements between connected entities.
• A consultation document was issued in relation to the
hybrid mismatch arrangements. The proposals largely
work is required e.g., regulatory capital. The new rules are
proposed to apply to payments made from 1 January 2017,
but no grandfathering provisions are proposed.
• The UK also made a statement on 20 September 2014
commit to implementing the new country-by-country
reporting template. The UK had initiated the country-by-
project to strengthen international standards on BEPS.
2.10 Pending tax proposals
•
contained many tax policy announcements. These will
generally be legislated in the Finance Bill 2015:
•
• Increase in the tax-free personal allowance
• Corporation tax — bank loss relief restriction
•
• Corporation tax relief restriction on self-incorporation
• Business rates —cap increase at 2% in 2015–16
• Employer Social Security — abolish for apprentices under
25
• Business rates — small business relief extension and retail
discount
• Enveloped dwellings — increase charge for properties over
£2m
• Air passenger duty — exempting children
• Non-domiciles — increase remittance basis charge
•
•
• Investment managers’ disguised fee income
• Corporation tax — accounting treatment of credit losses
• Stamp duty on shares — schemes of arrangement
• Corporation tax —anti-hybrids changes and country by
country reporting
• Special purpose share schemes
•
• Peer-to-peer lenders — relaxing the withholding tax regime
•
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188 | The outlook for global tax policy in 2015