Two key proposals designed to simplify taxation of their businesses and shareholders by replacing the current set-up with a single layer and align tax treatment with commercial reality have been submitted to the Treasury.
One involves giving medium-sized companies the opportunity to elect to be taxed as if they were partnerships or sole proprietors to produce a single tax level for business profits.
The second would extend the real estate investment trust regime to include all privately owned businesses, freeing them of corporation tax but paying taxable dividends to shareholders.
It’s a scary experience, pre-empting the treasury. As I wrote last month, such a move could be remarkably effective at tackling tax avoidance. It is a lot harder for individuals to avoid tax than it is for businesses to, if for no other reason than that individuals have an actual corporeal existence and find it significantly harder to be “headquartered” in a country they’ve never actually been to.
The Telegraph quotes the senior tax partner of the consultancy which drew up the reforms as suggesting that the changes as described would not reduce the tax take. That seems doubtful – especially the former suggestion, since allowing companies to elect to change their taxation rate all-but-guarantees that the only companies which take up the offer are those which would lower their taxable income by doing so. Realistically, such a move would have to be combined with an increase in the dividend tax rate to keep the tax take level. That increase would then probably require an increase in the marginal tax rate – at least at the top – to retain the incentives to investment in the current tax system… which means that it’s a policy move which no politician would touch with a ten-foot pole.
Still, we can but dream. If the Treasury does take up the policy, expect it to focus more on the “making companies pay less tax” aspect of it, which is far more in line with previous moves.