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    Businesses must prepare for £18 billion corporation tax increase

    Following the Chancellor’s decision to reinstate the Corporation Tax increase in the Medium-Term Fiscal Plan, the £18 billion tax hike will go ahead as planned from 1 April 2023.

    The Corporation Tax rate is currently 19%, and will rise to 25% in April, raising an estimated £12 billion in the first year, rising to £18 billion by 2025/26, with a system of tapered relief for companies with profits of between £50,000 and £250,000. The significant increase and additional tax burden could lead to a significant reduction in investment and even increase the risk of businesses closing, especially given the current economic climate with rising interest rates and inflationary pressures.

    The tax burden businesses are facing is higher than we have seen in the last two decades, with owner managed businesses likely to feel the biggest impact. These types of business owners may be unable to consider inward investment to grow as they may need to retain their profits to pay their household bills.

    Planning for an increase of this scale means it is more important than ever for SMEs to actively manage their corporate tax liabilities, and take full advantage of available tax reliefs to their liquidity, including:

    • Maximising the Annual Investment Allowance (AIA) of £1m
    • Claiming R&D tax relief
    • Increasing pension contributions
    • Maximising benefits for your team and focus on employee wellbeing
    • Considering electric vehicles

    If you are considering moving forward with an option outlined above, we would recommend speaking to your adviser before taking any action.

    Get in touch

    For more information, or to discuss your specific circumstances in more detail, contact corporate tax director, Claire Astley, by clicking the button below.

    Rising interest rates and the impact on Corporation Tax payable

    As you may be aware, from April 2023, the main rate of Corporation Tax (CT) will rise from 19% to 25%. This, paired with ever-increasing interest rates, could have a big impact on cash flow.

    The Bank of England base rate has been rising for some time and currently stands at 3.5%. This in turn leads to HMRC increasing interest charged on the late payment of tax.

    For a business that doesn’t pay within one of the large company instalment regimes, tax owed is due 9 months and 1 day after the year end. If tax is paid late, interest will be charged at base rate plus 2.5% per annum on the outstanding balance. The current late payment interest rate is 6%, a rise of 3.25% since January 2022

    It’s also worth mentioning that the repayment interest receivable on amounts overpaid has also increased. This is currently set at base rate less 1%. For a large company that falls into the instalment regime, the rate of interest on under paid instalments of CT is set at base rate plus 1%. The current instalment debit interest rate is, therefore, 4.5%, a rise of 3% since February 2022.

    Credit interest received on overpaid quarterly instalments or early payments of CT has increased to base rate less 0.25%, currently standing at 3.25%. If you are business owner who pays CT via the large scheme (annual taxable profits between £1.5 million and £20 million) or the very large scheme (annual taxable profits over £20 million), and you therefore pay tax in quarterly instalments, the rising interest rates, which we expect to rise further to control inflation in the coming months, could significantly increase the cost of your payments.

    Following the tax rate change in April 2023, large companies making instalment payments based on their expected tax liability for straddle periods should consider increasing their payments if they wish to avoid interest charges.

    For further information on the upcoming CT rate increases, read our recent blog by clicking here.

    Get in touch

    If you would like further advice based on your specific circumstances, please contact corporate tax assistant manager, Andy Kirkaldy, by clicking the button below.

    Increase in corporation tax rate to 25% from 1 April 2023

    Jeremy Hunt’s Autumn Statement last week confirmed that the previously cancelled planned increase in corporation tax from 19% to 25% will go ahead from 1 April 2023.

    This means that companies with anything other than a 31 March year end will face a blended tax rate for the accounting period straddling 1 April 2023 as follows:

    Accounting period endedTaxable profits < £50,000Taxable profits > £250,000Marginal rate between £50,000 & £250,000
    30 June 202319%20.5%20.875%
    30 September 202319%22%22.75%
    31 December 202319%23.5%24.625%
    31 March 2024 onwards19%25%26.5%

     

    There are things that can be done to minimise the impact of this increase; however, it is necessary to bear in mind that most of these options do result in tax payments being made earlier than they would be if no planning was done. Companies need to weigh up their cash position against their desire to minimise their tax liabilities.

    Options include:

    – If your year end is around the date of rate change, consider whether you can influence when profits or gains will arise. You may prefer them to arise earlier at the lower rate.

    – If you will have a straddle period and have made large profits early in the year, consider shortening the year-end to 31 March so that all your profits are taxed at 19%.

    – Brought forward tax losses that have arisen since April 2017 do not need to be utilised in a particular accounting period, they can be carried forward and used in a later accounting period to save tax at a rate of 25% rather than 19%.

    – Loss making companies may wish to carry losses forwards to use against future profits so saving tax at a rate of 25% rather than carrying a loss back to generate a repayment of tax at 19%.

    – The super deduction will also end on 31 March 2023. As the super deduction effectively gives tax relief at 25% there is little benefit to bringing forward capital expenditure. However, larger companies or groups with significant capital expenditure that is expected to exceed the annual investment allowance limit of £1 million should consider bringing forward qualifying capital expenditure to make use of the super deduction which, unlike the annual investment allowance, has no limit on the amount of expenditure that is claimed in an accounting period.

    – The awarding of bonuses or payment of pension contributions could be delayed until a later date to save tax at the higher rate.

    – If substantial capital assets are to be sold and trigger a capital gain, consider whether to exchange contracts and crystallise the gain pre or post 31 March 2023.

    – Property development companies that have a known sale of a development post 31 March 2023 could consider selling the development to a group company before 31 March and paying the corporation tax on the development profit at 19%. The sale post year end would then have a minimal profit taxable at 25%. This planning would only work in very specific circumstances and companies would need to be sure that the final sale will go ahead.

    – Instalments – large companies making instalment payments based on their expected tax liability for straddle periods will need to consider increasing their payments if they wish to avoid interest charges. The interest rate on instalment payments now stands at 3.25%.

    These are just a few outline ideas which could be considered in order to minimise the impact of the corporation tax increase. If you are considering moving forward with an option outlined above, we would recommend speaking to your adviser before taking action.

    For more information, please contact corporate tax director, Claire Astley, by clicking the button below, or corporate tax assistant manager, Mark Richmond (mark.richmond@pmm.co.uk).

     

    Autumn Statement 2022 – what can we expect?

    The much-anticipated Autumn Statement on 17 November is going to be crucial in laying out the government’s economic approach for the next few years. Rishi Sunak has already committed to a ‘low tax, high growth’ economy, and the Chancellor, Jeremy Hunt, promises to create confidence and stability in the UK economy, whilst lowering debt – a challenging balancing act.

    What can we expect in the upcoming Autumn Statement, and what measures do we believe the PM and his Chancellor should focus on to achieve short-term (and long-term) growth?

    Tax cuts

    It seems clear that the tax cuts briefly promised by Liz Truss and Kwasi Kwarteng are not going to happen and, in all likelihood, we will all end up paying more tax rather than less for the next few years.

    Corporation tax

    We already know that the corporation tax rate is set to increase from 19% to 25% on 1 April.  The question is what else will be done to business taxes?

    One suggestion is a scaling back of the currently very generous R&D tax credit regime.  A recent report commissioned by the government illustrates that for every £1 of tax relief, the large company RDEC scheme generates more investment by businesses that the more generous SME scheme.  We may therefore see a scaling back or even abolition of the SME scheme.   Much of this has been fuelled by abuse of the scheme by a minority of unscrupulous businesses and advisers and it is unfortunate that this could spoil the relief for those using it legitimately to fund much needed R&D.

    Income tax

    To achieve the sort of tax increases that we need to get the national finances back on track, only income tax, National Insurance and VAT are big enough taxes to make a difference quickly.  Changing the rates of these taxes would mean breaking the triple lock, a core manifesto pledge.  It remains to be seen whether the Prime Minister and Chancellor are brave enough and have the political backing to do that.

    What is probably more likely is an extension of the fiscal creep approach which we have already seen Rishi Sunak apply when he was Chancellor, by further extending the freeze on income tax rate thresholds.  Meaning that more and more taxpayers will be dragged into paying tax and moving up into higher tax rate bands over the next few years.

    We could also see some increases in dividend tax rates.  We already know that the health and social care surcharge, which has been abolished for earnings, will remain for dividends.  The question is whether the chancellor will take that a step further and choose to add further to dividend tax rates.

    Support for hospitality – cut to VAT?

    Although the government have previously recognised the damage caused to the hospitality industry throughout the pandemic, the cost of living and energy crises may be the final straw for many businesses that have barely recovered from the forced closures over the past two years. A reintroduction of the 5% reduced rate of VAT could go some way to support the hospitality industry through the Winter.  Whether that will happen remains to be seen.

    Capital gains tax

    Whilst capital gains tax provides only a small part of the overall tax take, we periodically see debate about whether rates will increase, which in turn provokes a flurry of activity and business sales.

    Rumours are currently circulating that the Chancellor may choose to increase the headline rate of capital gains tax or that he may choose to tweak, restrict or possibly even abolish the principle private residence exemption which currently exempts gains on selling your main residence from tax.  If so, it may be that there is a window of opportunity before changes taking effect on 6 April, although that could have a challenging impact on the property market if property investors or second home owners rush to dispose of them before tax rate changes take effect.

    The UK energy market

    As we all know, the government needs to fix the UK energy market. Part of that solution in the short term is ensuring businesses are less reliant on ‘purchased’ power by increasing their green credentials. Although businesses do currently receive tax relief on investments into green and renewable equipment, it isn’t enough to make it economically viable for most companies to really make the commitment.

    Investment in renewable energy usually sees a payback in 5-7 years, therefore, the introduction of an interest-free loan scheme to promote investment in renewables could be a solution – smoothing out energy costs. Alternatively, accelerated, or enhanced tax relief for companies who do invest in green and renewable equipment (similar to R&D tax relief) could be something else the government consider.

    The property market

    Possible solutions the government may be considering to help solve the housing crisis include:

    • Introducing an annual tax on second homes
    • Tax relief on mortgage interest for first time buyers
    • Stamp Duty exemption for homeowners who are downsizing

    Further strategies could include:

    • VAT exemption on home improvements that reduce energy consumption and reduce carbon emissions

    Pensions and investments

    It is likely that we will see some fiscal creep in the freezing of the pension lifetime allowance at its current £1,073,000 for a further 2 years, thus dragging more pension savings into tax.

    We may also see the Chancellor finally biting the bullet and removing higher rate income tax relief for pension contributions.  Whether this would happen immediately or on 6 April remains to be seen, but if you are planning a lump sum pension contribution soon, making it this week would perhaps make sense.

    Making tax digital

    The next phase of the government’s masterplan to create a real time tax system is Making Tax Digital for Income Tax (MTD for ITSA).  This is due to come into effect on 6 April 2024, meaning that self employed people and landlords will need to start planning for it and moving to MTD compatible digital accounting systems next year.

    It seems clear that there is some way to go for HMRC and the various software houses to get into a position where a viable system will work and, for this reason as well as the fact that it will impose additional compliance costs on taxpayers at a time when many other costs are increasing, we have seen the major accountancy bodies calling for a deferral of the introduction of MTD for ITSA.  I very much hope that the Chancellor listens to this and pushes it back to allow time for a more orderly introduction.

    Get in touch

    Clearly all of the above is speculation.  We will need to wait until 17 November to see what will actually happen to our taxes.

    If however you would like to discuss any of the matters discussed in this article, contact your usual PM+M adviser, or get in touch with Jane Parry by clicking the button below.

    Ensure you are up to date with the Chancellor’s announcements in the upcoming Autumn Statement by attending our seminar on 18 November at Stanley House. Our panel of experts will be providing valuable insights into what the government’s plans mean for you and your business. Find out more and book your place by clicking here.

    The Growth Plan – an Update  

    On 14 October, as an important deadline loomed for Bank of England support of the government bond markets to expire, the government’s political turmoil ratcheted up as the fallout from the ‘fiscal event’ of 23 September claimed its first scalp.

     

    A new Chancellor

    Jeremy Hunt replaced Kwasi Kwarteng as Chancellor, making him the fourth Chancellor in as many months.

    Chris Philp, the Chief Secretary to the Treasury, was also sacked. He was replaced by Ed Argar, formerly the Paymaster General and Minister to the Cabinet Office.

     

    Corporation tax

    At a press conference (the House of Commons was not sitting), the Prime Minister announced that the planned reversal of the increase to corporation tax would not go ahead. The rise from April 2023 to a main rate of 25%, with reduced rates for companies with profits below £250,000, was legislated for in the Finance Act 2021.

    31 October remains the date when the Medium-Term Fiscal Plan will be announced. The Prime Minister said that the £18bn tax savings from the corporation tax reversal was a ‘down payment’ on this strategy. That still leaves a shortfall of about £24bn in 2026/27 stemming from September’s announcement.

    Spending, said Liz Truss, would grow ‘less rapidly than previously planned’.

     

    Timetable of reversals

    Today’s announcements were the culmination of a series of statements and retractions over the last few weeks:

    • On 26 September the previous Chancellor, Kwasi Kwarteng issued an ‘Update on Growth Plan Implementation’ revealing that his Medium-Term Fiscal Plan would be presented on 23 November, alongside a forecast from the Office for Budget Responsibility (OBR).

     

    • The planned abolition of the 45% tax rate announced in September’s ‘mini-Budget’ survived just ten days before being reversed on 3 October.

     

    • Seven days later, on 10 October, the Treasury announced that the Chancellor would bring forward the announcement of his Medium-Term Fiscal Plan from 23 November to 31 October.

     

    This last date for the calendar is one of the surviving elements of Kwasi Kwarteng’s planning which Jeremy Hunt will now take forward.

     

    The next few weeks will be very interesting for many businesses, and individuals, and upcoming announcements may cause you to rethink your short- and medium-term plans. We will be sure to keep our clients and contacts updated as further detail from the government emerges.

     

    Liz Truss announces increase in corporation tax rate to 25% from 1 April 2023

    Today (14 October 2022) after much speculation the Prime Minister has announced that the previously cancelled planned increase in corporation tax from 19% to 25% is now back in place.

    The increase in the corporation tax rate will take effect from 1 April 2023.  That means companies with anything other than a 31 March year end will face a blended tax rate for the accounting period straddling 1 April 2023 as follows:

     

    Accounting period endedTaxable profits < £50,000Taxable profits > £250,000Marginal rate between £50,000 & £250,000
    30 June 202319%20.5%20.875%
    30 September 202319%22%22.75%
    31 December 202319%23.5%24.625%
    31 March 2024 onwards19%25%26.5%

     

    There are things that can be done to minimise the impact of this increase; however, it is necessary to bear in mind that most of these options do result in tax payments being made earlier than they would be if no planning was done. Companies need to weigh up their cash position against their desire to minimise their tax liabilities.

    Options include:

    • If your year end is around the date of rate change, consider whether you can influence when profits or gains will arise. You may prefer them to arise earlier at the lower rate.
    • If you will have a straddle period and have made large profits early in the year, consider shortening the year-end to 31 March so that all your profits are taxed at 19%.
    • Brought forward tax losses that have arisen since April 2017 do not need to be utilised in a particular accounting period, they can be carried forward and used in a later accounting period to save tax at a rate of 25% rather than 19%.
    • Loss making companies may wish to carry losses forwards to use against future profits so saving tax at a rate of 25% rather than carrying a loss back to generate a repayment of tax at 19%.
    • The super deduction will also end on 31 March 2023. As the super deduction effectively gives tax relief at 25% there is little benefit to bringing forward capital expenditure. However, larger companies or groups with significant capital expenditure that is expected to exceed the annual investment allowance limit of £1 million should consider bringing forward qualifying capital expenditure to make use of the super deduction which, unlike the annual investment allowance, has no limit on the amount of expenditure that is claimed in an accounting period.
    • The awarding of bonuses or payment of pension contributions could be delayed until a later date to save tax at the higher rate.
    • If substantial capital assets are to be sold and trigger a capital gain, consider whether to exchange contracts and crystallise the gain pre or post 31 March 2023.
    • Property development companies that have a known sale of a development post 31 March 2023 could consider selling the development to a group company before 31 March and paying the corporation tax on the development profit at 19%. The sale post year end would then have a minimal profit taxable at 25%. This planning would only work in very specific circumstances and companies would need to be sure that the final sale will go ahead.
    • Instalments – large companies making instalment payments based on their expected tax liability for straddle periods will need to consider increasing their payments if they wish to avoid interest charges. The interest rate on instalment payments now stands at 3.25%.

     

    Get in touch

    The above are only a a limited number of outline ideas and you should seek specific advice tailored to your circumstances before taking or refraining from any action. For more information,  please contact Claire Astley by clicking on the button below.

    Companies reminded to take advantage of the 130% ‘super-deduction’ before it ends

    The 130% ‘super-deduction’, announced in the Spring Budget in 2021, was introduced to incentivise company investment. For expenditure incurred until the end of March 2023, companies can claim 130% capital allowances on qualifying plant and machinery purchases.

    Under the ‘super-deduction’, firms are able to cut their taxes by up to 25p for every pound they invest.

    It seems many companies who may still be recovering from the coronavirus pandemic have not yet taken advantage of the special tax relief.  Covid-19, coupled with the war in Ukraine, may have made companies reluctant to invest until the political and economic situation stabilises.

    How does the ‘super-deduction’ work?

    Businesses that claim in time could see tax savings of up to 25p for every £1 that they invest, meaning a £1million investment could see a corporation tax saving of £247,000, compared with just £190,000 under the previous system.

    What is classed as plant and machinery?

    For the purposes of claiming capital allowances, many tangible capital assets used in the course of a trade are considered plant and machinery.

    There is not an exhaustive list of plant and machinery assets, but we have listed some examples below:

    – Computer equipment and servers

    – Tractors, lorries and vans

    – Ladders, drills, cranes

    – Office chairs and desks

    – Carpets

    – Refrigeration units

    – Compressors

    – Foundry equipment

    Are there any exemptions?

    To be eligible for the ‘super-deduction’, the plant and machinery purchased must be new (second hand assets do not qualify) and not used for leasing although assets purchased for use in a commercial building that is leased out, do qualify.

    Additionally, only companies within the charge to corporation tax qualify for the relief, sole traders and partnerships do not.

    Get in touch

    If you are interested in taking advantage of the ‘130% super-deduction’ but have concerns or questions around utilising the scheme, please speak to your usual PM+M representative or get in touch by emailing enquiries@pmm.co.uk.