On Friday 6 July 2018, the draft clauses of Finance (No.3) Bill (which we will refer to as Draft Finance Bill 2018/19) were released, along with explanatory notes and tax information and impact notes (TIINs).
Despite expectations that there would be announcements relating to taxation of the digital economy, an expanded royalty withholding tax scope and the corporate intangible fixed assets regime, none of these have materialised. However, some of the key measures in Draft Finance Bill 2018/19 include:
The draft legislation is now available for consultation until 31 August 2018, with the final contents of Finance Bill 2018/19 subject to confirmation at Autumn Budget 2018.
Our analysis of the key measures can be found below.
Finance Bill 2018-19 includes two new measures which amend decommissioning tax relief for corporation tax and Petroleum Revenue Tax purposes.
Currently HMRC have four, six or 20 years (for mistake, careless or deliberate behaviour respectively) to assess tax that is due. Draft legislation issued on 6 July 2018 has extended the four and six year time limits such that HMRC will always be able to assess at least 12 years of back taxes for offshore non-compliance.
HMRC reveals the remaining detail of their tax response to IFRS16, including its interaction with CIR.
Draft Finance Bill 2018/19 included several anti-avoidance measures – this article highlights two key points.
New rules for gains on direct and indirect disposals of UK property by non-residents and changes to tax on rental income of non-resident companies
On the whole Draft Finance Bill 2018/19 did not contain any big surprises for multinational businesses, with the majority of the measures either implementing previously announced policy changes, or making smaller scale changes.
Some other items of note from Draft Finance Bill 2018/19.
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