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Topic: Mainstream Corporation Tax

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	United Kingdom corporation tax - Wikipedia, the free encyclopedia
		Corporation tax is the next area scheduled to be tackled by the tax law rewrite project and it is thought that two Acts of Parliament will be required to bring it into line with the aims of the project.
		Tax competition between jurisdictions has reduced the headline charge to 30%; judgments from the European Court of Justice have found that certain aspects of UK corporate tax law are discriminatory under European Union treaties; and tax avoidance schemes marketed by the big accountancy and law firms and by banks have threatened the tax base.
		Corporation tax was introduced as from 1 April 1965 by the then Chancellor of the Exchequer James Callaghan.
	en.wikipedia.org /wiki/United_Kingdom_corporation_tax (5102 words)

	Oce van der Grinten (Taxation) [2003] EUECJ C-58/01 (25 September 2003)
		Corporation tax is charged on the profits of a company arising during an accounting period (sections 6(1) and 8(1) and (3) of ICTA), which is normally 12 months (section 12 of ICTA).
		The tax credit is a fiscal instrument designed to avoid double taxation, in economic terms, first in the hands of the subsidiary and then in the hands of the parent company in receipt of the dividends, of the profits distributed as dividends.
		The withholding tax at issue in the main proceedings may accordingly be regarded as falling within a body of agreement-based provisions relating to the payment of tax credits to the recipients of dividends and as designed thereby to mitigate double taxation.
	www.worldlii.org /eu/cases/EUECJ/2003/C5801.html (5380 words)

	[No title]
		Similarly, if the United Kingdom subsidiary surrenders its "advance corporation tax" to a second-tier subsidiary, then the provisional credit allowed to the corporation that paid the advance tax is reversed and the advance tax is allowable as a credit in the year it is applied against the "corporation tax" liability of the second-tier subsidiary.
		Where ACT is used to offset mainstream tax, the offset will be viewed as a refund of the ACT initially allowed as a credit and as a tax paid in respect of the year for which the ACT is applied as an offset.
		If accrued taxes when paid differ from the amounts claimed as credits by the taxpayer, or if any tax paid is refunded in whole or in part, the taxpayer shall notify the Secretary or his delegate, who shall redetermine the amount of tax for the year or years affected.
	www.usdoj.gov /osg/briefs/1994/w942005w.txt (14541 words)

	What is United Kingdom corporation tax? : Abaara fun facts and uncommon knowledge - United Kingdom corporation tax (Site not responding. Last check: 2007-09-21)
		Corporation tax is a tax levied in the
		Corporation tax is charged in respect of accounting periods, which usually coincide with the 12 month period for which most companies prepare accounts known as financial statements.
		August 2003 by Corporation tax reform - A consultation document, which further discussed the possible abolition of the Schedular system, and also whether the capital allowances (tax depreciation) system should be abolished.
	info.abaara.com /pac/United_Kingdom_corporation_tax (3133 words)

	CIOT \| The Chartered Institute of Taxation: Reform of Corporation Tax
		The corporate sector has a number of compliance burdens to face over the next 2-3 years (including the introduction of IAS which we raise in a related context below) and should not be burdened further by “rushed” reforms.
		It cannot be stated too strongly that because corporation tax is payable in cash, the basis of computation must take into account the extent to which transactions or revaluations generate cash either immediately or in the short term (i.e.
		Corporation tax is by no means the most significant tax burden or distortion facing small businesses.
	www.tax.org.uk /showarticle.pl?n=&id=1433&p=1 (1677 words)

	HM Revenue & Customs: Corporation Taxation
		The lower section of the table shows annual receipts of both mainstream tax and ACT and for 1998-99 to 2001-02 it also shows the amounts to be paid under the new instalment regime.
		The receipts of mainstream tax in each financial year are shown directly below the years (in the top section) when most of the tax accrued.
		Tax charged on corporate gains is not accounted for separately in tax receipts and therefore rounded estimates are provided as a memorandum item in the above table.
	www.hmrc.gov.uk /stats/corporate_tax/ct_t01_1.htm (520 words)

	Online Accountancy - theaccountsoffice.co.uk
		In recent years the UK tax system has seen a number of significant changes and it is now seen as one of the most complicated regimes in the world.
		Corporation tax is assessed on the adjusted trading profits and other income of UK resident companies.
		It is the employer's duty to deduct income tax from the pay of his or her employees regardless of whether or not he or she has been instructed to do so by the Tax Office.
	www.btinternet.com /~alexandergrant/accountsoffice/taxation.htm (455 words)

	Irish Business News, July 29, 1998
		With non-manufacturing corporation tax scheduled to fall to 12·5% by 2003, Ireland looks set to be extremely attractive for firms operating in the sector, according to Jim Power, chief economist with Bank of Ireland Group Treasury.
		Last week, the Government announced that it had reached agreement with the EU Commission to reform corporation tax, removing the uncertainty about the structure likely to apply after the expiration of the current 10% level on certain manufacturing, and internationally traded and financial activities.
		With effect from 1999, the mainstream corporation tax rate will be lower than that applying in those countries from which the bulk of the country's inward investment is currently sources.
	archives.tcm.ie /irishexaminer/1998/07/29/bhead.htm (3880 words)

	Digita.com: Digita Corporation Tax (Site not responding. Last check: 2007-09-21)
		Digita Corporation Tax software completes both the tax computation and the relevant tax forms for all chargeable periods created and in addition there is a deferred tax calculator which can be used to calculate the amounts required for provision under FRS 19.
		Digita Corporation Tax automatically calculates profits chargeable to corporation tax for trading and investment companies, and the mainstream corporation tax chargeable incorporating marginal small companies relief (if applicable).
		Similarly, for non-corporate distributions, Digita Corporation Tax will calculate the maximum profits available and also apply the matching rules to the distributions made from the profits of the period.
	www.digita.com /professional/home/products/cotaxpro/default.asp (725 words)

	CIOT \| The Chartered Institute of Taxation: Discriminatory UK tax law
		Although Hoechst UK Ltd was able to set the ACT paid against its mainstream corporation tax liability, the ECJ ruled that the company is entitled to compensation for the financial loss sustained — in other words, the loss of use of its cash resulting from the early payment of corporation tax.
		They may well hold that the proper construction of the non-discrimination clause of an appropriate double tax treaty is not to compare the position with that which would apply if the parent were UK resident, but to compare the situation with that applying to a UK company owned by a resident of some other state.
		Individual UK resident shareholders are taxed at a maximum rate of 32.5 per cent on dividends from UK companies, with a tax credit of ten per cent.
	www.tax.org.uk /showarticle.pl?n=&id=623&p=1 (2441 words)

	Sempra Metals v. IRC [2004] EWHC 2387 (Ch)
		(iii) To a similar effect paragraph 89 referred to 'interest accrued on the advance corporation tax paid by the subsidiary during the period between the payment of advance corporation tax and the date on which mainstream corporation tax became payable', and continued to say that 'that sum may be claimed by way of restitution'.
		In the main proceedings, however, the claim for payment of interest covering the cost of the loss of the use of the sums paid by way of advance corporation tax is not ancillary, but is the very objective sought by the claimants' actions in the main proceedings.
		In such circumstances, where the breach of Community law arises, not from the payment of the tax itself but from its being levied prematurely, the award of interest represents the 'reimbursement' of that which was improperly paid and would appear to be essential in restoring the equal treatment guaranteed by article 52 of the Treaty.
	www.ucc.ie /law/restitution/archive/englcases/sempra.htm (7339 words)

	Startups \| Print this page (Site not responding. Last check: 2007-09-21)
		Corporate Venturing UK (CVUK) said that although large firms are offered tax breaks to help develop startups, many feel that the process is still not attractive enough to invest in.
		CVUK said that although motivations behind corporate venturing are usually not purely financial, the lack of genuinely enticing tax incentives through the Corporate Venturing Scheme (CVS) meant that many small firms were losing out.
		CVUK said that this threshold should be raised to 30 per cent, in line with mainstream corporation tax.
	www.startups.co.uk /common/print.aspx?a=21426f17&h=4783c25f (311 words)

	TaxNewsFlash-Europe
		The AG’s opinion concerned the UK corporate income taxation rules that proscribed different tax treatment of domestic dividends (tax exempt) from inbound dividends (taxed but with a credit granted for foreign withholding and underlying corporate tax).
		The AG noted that ACT cannot be considered to be a withholding tax because it is not levied against the receipt of foreign dividends—but rather on the re-distribution of such profits.
		The UK rules that were introduced on July 1, 1994, with the aim to mitigate the disadvantages related to the receipt of foreign-source dividends and that contained the possibility for UK-resident companies to elect that a dividend which it distributed to be a “foreign income dividend”.
	www.us.kpmg.com /microsite/TNF-Europe/2006/Apr/TNFEUR06_17UK.html (1530 words)

	Corporation Tax.
		For example, when the standard corporation tax rate on trading income is 12.5%, half of the trading loss will be allowed against income taxable at the 25% rate.
		Qualifying shipping activities will be subject to a special tonnage tax regime instead of the normal corporation tax regime for accounting periods ending on or after 1st January, 2002.
		The standard rate of Corporation tax (16% for 2002) is then applied to the profits.
	www.boylandodd.com /ct.html (1009 words)

	Ireland's offshore tax and legal regimes
		The tax advantages of the Free Zone can often be combined with Ireland's network of Double Tax Treaties to obtain a very favourable outcome; however, some tax treaties disallow withholding tax exemptions for companies not paying a 'normal' rate of tax.
		A company which did not qualify as a true 'manufacturing' company paid the declining rate of mainstream corporation tax (see Domestic Corporate Taxation) from 2001 until the final 12.5% rate agreed between the Irish Government and the EU came into effect in 2003.
		A non-resident individual pays income tax only on Irish-sourced income, and is liable to capital gains tax only on gains arising in Ireland or remitted to Ireland, unless he is domiciled in Ireland in which case he is liable on all capital gains.
	www.lawandtax-news.com /html/ireland/jirlatoltr.html (2404 words)

	Jonathan Schwarz - Barrister
		The scope of the expression "withholding tax" in the Directive was, however, too vague to enable him to decide with the requisite level of confidence whether the 5% tax was a withholding tax within the context of Article 5(1) of the Directive and therefore the question should be referred to the European Court of Justice.
		In addition, the tax credits and their payment were, as far as UK tax law was concerned, an essential feature of the system of tax on dividends.
		Jacob J held that whether a particular national law was characterized as a "tax" as a matter of national law was immaterial to the question of whether it was a withholding tax as a matter of Community law.
	www.jschwarz.demon.co.uk /jseccases.html (1862 words)

	Murdoch groups top low taxpayers' league (Site not responding. Last check: 2007-09-21)
		News will not discuss tax, but the 1995 accounts disclose that it had used tax losses to offset its corporation tax liability and still had at least £250m in unused losses left.
		British Airways cuts its tax bill by leasing aircraft; the costs are treated as hire purchase by the Revenue.
		Rank and Reckitt & Colman's 1995 tax rates were reduced by the inclusion of large tax free capital gains in their profits, while Hanson benefits from depletion allowances and environmental tax concessions on its US natural resources business.
	telegraph.co.uk /htmlContent.jhtml?html=/archive/1996/11/30/ctax30.html (378 words)

	Reeves & Neylan Chartered Accountants Kent: Key Dates & Deadlines
		Deadline for submitting personal tax returns for 2004/05 where the taxpayer wishes the Revenue to calculate the liability or prefers any underpayment (up to Â£2,000) to be coded out in 2007/08.
		Child and Working Tax Credit claimants should submit their final figures for 2005/06 by today, or an estimate, with final figures by 31 January 2007, failing which the payments of Tax Credits will be suspended.
		Tax and Class1B National Insurance contributions due under PAYE Settlement Agreements for 2005/06 to be paid by today.
	www.reeves-neylan.com /accountancy/Template.aspx?pid=94 (1649 words)

	Untitled
		Corporation tax rates, thresholds and marginal rate relief fractions all remain unchanged for the financial year 2001/02.
		Extension of the capital gains tax taper relief for business assets to employees of non-trading companies, provided that the individuals have no more than a 10% interest in the company.
		Thus, parents who fund the contributions of their children will be liable to tax on any interest exceeding £100 a year.
	www.shrm.org /global/publications/watson-wyatt/0201budget.htm (1763 words)

	[No title]
		Under section 247 of the Income and Corporation Taxes Act 1988 the law is that where a parent receives a dividend from its parent they can make a 'group income election.' If they make the election then Advance Corporation Tax is not payable.
		Her further point also stands that this general approach is replicated in many other tax statutes and that it would be undesirable to let the Revenue escape restitutionary liability across the board wherever tax liability is incurred on a 'liable until proved innocent' basis.
		What is left is a tax due under English law but also due under EU law, unless EU law says that the consequence of unlawfully failing to offer the election to some taxpayers is that they shall be allowed to exercise it retroactively.
	www.ucc.ie /law/restitution/rdg_rawtext/restitution.0505.txt (13988 words)

	FINANCIAL ADVICE - The Green Budget (Site not responding. Last check: 2007-09-21)
		The main thrust of the document was a detailed summary of changes to corporation tax that will be introduced in 1999.
		The new legislation will remove the present inequity that can arise when a dividend is paid after the end of an accounting period resulting in a payment of ACT which does not reduce the mainstream corporation tax liability of that year.
		The only bad news for contractors is that while the main rate of corporation tax will reduce by one per cent to 30 per cent from 1 April 1999, there will be no corresponding reduction in the small companies rate.
	www.computeractive.co.uk /articles/print/2047760 (706 words)

	Consulco offshore business services in Cyprus - EUROPEAN UNION; UNITED KINGDOM
		Although dividends received by one UK resident company from another were exempt, they carried a tax credit equal to the ACT payable on the dividend, which could be used by the receiving company to frank dividends that it paid to its own shareholders.
		Where an EU Member State has a system which in certain circumstances imposes ACT on the payment of dividends by a resident company to its shareholders and grants a tax credit to shareholders resident in that EU Member State in respect of those dividends, is it contrary to Arts.
		In exercising such jurisdiction, national courts are, however, obliged to ensure that the claimants have an effective legal remedy in order to obtain reimbursement or reparation of the financial loss, which they have sustained as a direct result of tax levied in breach of Community law.
	www.consulco.com /EN/tax_news/article1228 (2471 words)

	Ireland Offshore Legal and Tax Regime
		Irish banks now obliged to pass on details of savings income for taxation purposes to the Revenue Commission who are tasked with passing this information on to the tax authorities of the EU member state where the customer resides.
		Existing IFSC companies will retain their tax privileges until the end of 2004; but new IFSC companies receiving certificates after July 1998 paid 10% only until the end of 2002.
		After that, the tax rate will increase to the 12.5% mainstream rate of corporation tax agreed by the Irish Government with the EU, and coming into force generally from 1st January 2003.
	www.lowtax.net /lowtax/html/jiroltr.html (2413 words)

	National Statistics Online
		Data are available for the derivation of mainstream corporation tax liability from trading and non-trading income and tax reliefs.
		Until it abolition from 6 April 1999 receipts of Advanced Corporation Tax (ACT) were a...
		Data are available on tax expenditures, structural and mixed reliefs.
	www.statistics.gov.uk /CCI/nscl.asp?ID=7096 (232 words)

	Pensions News Flash - March 2001
		A Treasury press release also indicates that the Chancellor intends to restore to its original level the differential between the rate of tax on refunds of surplus to the employer and the rate of mainstream corporation tax.
		It seems, therefore, as if the rate of tax on refunds of surplus will be reduced to 35%.
		It also recommends that the tax rate (40%) on refunds of surplus to the employer be lowered, perhaps to the prevailing rate of mainstream corporation tax (currently 30%).
	www.watsonwyatt.com /europe/pubs/pensionflash/articles/2001_03_01.asp (1384 words)

	Corporation Tax: Mainstream Corporation Tax Receipts and Reconciliation with Tax Accruals
		The Inland Revenue Analytical Services Division compiles data on corporation tax receipts including from January 1999 quarterly instalment payments for large companies.
		Until it abolition from 6 April 1999 receipts of Advanced Corporation Tax (ACT) were available separately from receipts of mainstream corporation tax.
		They have been published annually since the partial imputation system for corporation tax was introduced in 1973-74, including estimates for the most recent completed year.
	www.statistics.gov.uk /STATBASE/Source.asp?vlnk=140&More=Y (116 words)

	Incorporation, Incorporation Services, Company Incorporation
		Premiums paid away to companies in countries with a mainstream corporation tax rate of less than 20% would not be deductible for corporate income tax purposes.
		Third, HR 1755 is simply a new tax being proposed by one set of competitors on another set of competitors.
		Neither Treasury nor Congress should be engaged in picking winners and losers in today's global economy, particularly based solely on the tax system of a foreign nation.
	www.companiesinc.com /cinewsletter/july2001/story4291.asp (1089 words)

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