After the raft of spending and investment measures announced by the Chancellor in today's Budget speech, one cannot help but feel a bit perplexed at the apparent lack of taxation measures announced to fund them. The most fundamental tax change (or, at least, the one with the most widespread impact) was of course announced last month with the 1.25% increases to dividend income tax rates and Class 1 and Class 4 National Insurance contributions. However we saw nothing today on CGT or IHT notwithstanding the pre Budget day industry chat.
The take home message from Budget day to British business continues to be to invest and innovate - with the Annual Investment Allowance frozen at £1m until April 2023, the reform of R&D tax reliefs and the introduction of 'improvement' relief from business rates. The Chancellor showed continued support for the hospitality, retail and leisure sectors with increases to theatre, orchestra and museums and galleries exhibition tax reliefs and a temporary business rates relief for 2022/23.
In the real estate sector the Chancellor confirmed that the new residential property developers tax (RPDT) will be introduced at 4% on companies or groups with annual profits from residential property development above a £25m annual allowance. The charge will apply from 1 April 2022 to relevant profits recognised in accounting periods ending on or after that date. Any accounting periods which straddle 1st April 2022 will have their profits time apportioned so only the element falling on or after 1st April 2022 will be taxed. Property investors including those in the Build to rent sector will not be caught by the charging provisions which will be a welcome boost to that area of the market. There seems to be no help however for those who have already taken steps to correct cladding issues on buildings which is a shame. The Budget detail also confirmed that the reporting window for residential property gains will increase from 30 days to 60 days after completion with immediate effect, following the OTS' recommendation. This is a helpful relaxation of what are still relatively new compliance rules.
Finance Bill 2021-2022 will also legislate for the 'basis period' reform that the Government has been consulting on, affecting sole traders and partners, to be introduced at a later date than originally envisaged - from 2024/2025, with transitional rules applicable in 2023/2024 - to allow businesses to prepare for the change. The impact of this change is likely to lead to a greater tax charge in the transitional year and many partnerships with a 30 April year end will be working the detail through.
Alongside the Budget documents, a new consultation on corporate redomiciliation to the UK has been published. It will be interesting to see the extent to which the Government intends to legislate for special tax rules for the treatment a company redomiciled to the UK can expect over a company 'born and bred' here.