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The Chancellor delivered his autumn statement on 29 November.


Download Corporate tax reform (PDF, 50  KB)
Download Deloitte's bulletin summarising the corporate tax reform proposals announced in the autumn statement.


The Government has produced its landmark Corporate Tax Reform discussion document today.

It puts forward:

  • Confirmation of the Patent box - initially put forward by Alistair Darling - to take effect from April 2013. This will offer a 10% tax on the income from newly-created patents.
  • A Review of the R&D tax credit regime, which has been in existence for ten years. There are suggestions that software should be excluded, but that consideration would be given to widening the categories of qualifying expenditure.
  • Confirmation that the UK will allow tax relief for interest expense, without restriction, apart from existing anti-avoidance rules.
  • It rules out consideration of a wider 10% tax regime for intellectual property income.
  • Limited liberalisation from 2012 of the UK's controlled foreign company rules - which levy UK tax on the foreign profits of overseas subsidiaries. It proposes an effective 8-9% tax charge on overseas finance income (ignoring incidental income relating to overseas trading businesses). It offers a limited exemption from UK tax on income from intellectual property - although much work remains on defining the exemption.
  • Introduction from April 2011 of an exemption for profits earned in an overseas branch of a UK company. Losses may be offset against UK profits, but only if the company opts for profits to be taxed as well.
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