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Tax Administration and Maintenance Day: Let the consultations commence

Posted on 17 May 2023

On 27 April 2023, known as "Tax Administration and Maintenance Day", the Government announced a package of tax policy proposals and consultations. The proposals aim to "make the UK tax system more simplified, modern and fair", to tackle non-compliance and to improve the customs system for traders.

The announcement built on the most recent Budget, and forms part of the Government’s 10-year tax administration strategy published in July 2020. This is the second of such events, the first having taken place in 2021.

Whilst no significant tax changes loom definitively from the announcements, there are proposals to review and consult on many taxes, including (among others):

  • Employee Ownership Trusts (EOTs): to ensure the reliefs are not used for “unintended tax planning”;
  • Stamp taxes: combining Stamp Duty on shares and Stamp Duty Reserve Tax (SDRT) to create a single tax on securities;
  • Gift Aid and donations to charities: seeking to minimise administrative burdens using digital technology and tackling non-compliance;
  • Construction Industry Scheme (CIS): reviewing the terms of landlord/tenant contributions and group reporting;
  • Diverted profits tax (DPT): likely increasing the rate of tax on diverted UK profits, which is currently set at 25% - the new top rate of UK corporation tax;
  • Transfer pricing: Reviewing the application in respect of related party transactions;
  • Permanent establishments: in respect of the right to tax non-resident entities with a UK business presence; and
  • A new "Reserved Investor Fund": intended to offer a UK-based fund that offers more flexibility and lower costs than other fund structures.

The various consultations are now open and will close in June and July. There was no consultation announced on the tax regime for non-domicilaries, despite speculation.

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