Budget 2017: Rocks in hard places

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Chancellor Philip Hammond faces a hard task in next week’s Budget. On his unenviable list of goals is to prepare the UK economy for the biggest legislative upheaval in living memory in the form of Brexit, and radically reform a creaking taxation system to address a shrinking tax base.

If the rumours swirling around Westminster prove to be true and this is to be Hammond’s last Budget, will he choose to go down in a blaze of legislative glory, enacting bold changes such as the reduction in the VAT threshold or merging income tax and NI, or will spreadsheet Phil play it safe and opt for a ‘only necessary changes’ approach?

This watching brief is a summary of changes that may or may not be announced on Wednesday:

National insurance

As previously announced, the merger of Classes 2 and 4 NIC (with the abolition of the former) has been delayed by a year to 6 April 2019. But uncertainty remains around what the rate for the new Class 4 NIC will be.

The last time the Chancellor dabbled with national insurance he received a swift rebuke from his Downing Street neighbour, so any prospect of this being revisited should be treated with caution.

Commenting ahead of the Budget, RSM’s tax partner George Bull said that while the underlying discrepancies in NI contributions between the employed and self-employed may be reduced by increases in Class 4 NIC from April 2018 and April 2019, some are saying that this does not go far enough, especially in light of the Taylor Review.

In a bid to help young employees there could be a reduction in contributions for those under a certain age, but this seems a stretch for a government under fiscal pressure.

Tax avoidance and evasion

While a raft of anti-evasion and avoidance measures are still bedding in, including the GAAR and the new corporate criminal offence of failing to prevent the facilitation of tax evasion, the recent Paradise Papers news splash will ratchet up the pressure on the Chancellor to talk tough on the perceived injustices of the system.

The use of disguised remuneration schemes has already been addressed by measures such as a new charge on disguised remuneration loans which remain outstanding on 5 April 2019. RSM’s George Bull told AccountingWEB that he hoped the Chancellor would use the Budget to clarify exactly how the loan change will be collected, and in particular on what basis on the liability for payment may be transferred from employers to employees.

Tax reliefs

One change the government may enact is the reduction of tax breaks offered by the Enterprise Investment Scheme (EIS), possibly by reversing the increase in 2011 of the income tax relief from 30% to 20%. Alternatively, the range of trades which can qualify for EIS may be reduced once more to exclude less risky enterprises, such as TV productions and property-holding businesses such as pubs or restaurants.

Another relief under threat, according to David Kilshaw, private client services partner at EY, is inheritance tax business property relief.

“We may see a cap on the value of that business property relief,” said Kilshaw, “which exempts unquoted trading companies from the inheritance tax charge on death.” This relief has been under scrutiny, and thus at risk for some years now.

MTD consultation papers

The government’s flagship digital taxation programme has been plagued with delays, but with Making Tax Digital for VAT due to start in 2019, it is highly likely that the government will publish further draft VAT regulations to support MTD implementation.

According to RSM’s tax director Andrew Hubbard, this secondary legislation is likely to make provisions for the content, form and means by which digital records are to be kept preserved, and identify exemptions from MTD for VAT.

Hubbard believes that MTD consultations for complex businesses and large partnerships are extremely unlikely to appear in this Budget.


The increasing of these rates or the lowering of thresholds for both SDLT and ATED have been money spinners for the government, and faced with increasingly gloomy economic forecasts may prove too tempting for the government.

In the same area, the Chancellor is also said to be pondering a possible SDLT holiday or reduction for first-time buyers, as he seeks to address the view that young people are increasingly priced out of the housing market.

VAT simplification

The release of the OTS simplification of VAT review provided the government with a perfect opportunity to gauge wider opinion on a diverse range of VAT measures, including the most controversial of them all, a reduction in the £85,000 registration threshold.

Other, less divisive measures could include consultations on penalties and appeals, special accounting schemes, simplifying VAT partial exemption, the option to tax and the capital goods scheme. The extent to which supplies which are subject to reduced VAT rates, or are exempt from VAT could be reviewed with greater freedom once the UK has left the EU.

IR35 and the Taylor Review

Given that the legislation is already in place for IR35 in the public sector, it would be relatively straightforward (legislatively speaking) for the government to extend this to the private sector without discussion or consultation - regardless of how controversial this is likely to prove.

Susan Ball, Employment Tax Partner at Crowe Clark Whitehall, believes we could see an announcement in this Budget with a start date of April 2018 or April 2019, as there are so many areas for affected organisations to contend with.

“We are now seven months into the change in the public sector,” commented Ball. “HMRC’s view is that the implementation has gone well, as almost all stakeholders who have been impacted by the changes have reporting problems and ongoing concerns.

“If we do not hear more on this, then we are likely to have a reporting back on the recommendations from the Taylor review and ‘dependent contractor’ status, together with a possible increase in NIC for the self-employed.”

Benefits in kind: a further tightening of conditions

Due to be published in the Spring Budget 2017, the call for evidence on how benefits in kind are valued for tax purposes has yet to be issued. RSM’s George Bull expects this to appear, along with the outcome of the call for evidence on the use of income tax relief for employees’ business expenses.

Pensions tax relief in the firing line

Previous Budgets brought with them radical changes to pensions, and Jason Whyte, associate partner, pensions at EY, believes there won’t be any fundamental alterations this time around.

However, pensions tax relief could be in the firing line, which is currently worth just under £40bn per year to savers. A further reduction in the annual allowance has been mooted, but the more likely target is to bring down the threshold for annual allowance taper from adjusted earnings of £150,000 pa to £120,000 pa.

Insurance Premium Tax

Another potential target for a revenue-hungry government could be Insurance Premium Tax. However, given that this has doubled from 6% to 12% in the last two years, with the most recent hike in June 2017, both insurers and customers will be hoping for a quiet Budget this time around.

Road fuel duty

Since the formation of the coalition government in 2010 the fuel duty stabiliser hasn’t been used. An increase in fuel duty by RPI at 3.9% would be expected to cost just over £1bn in 2018-19, according to ONS figures. With a government looking for quick cash and the recent diesel revelations this may be an easy way to fill a fiscal hole.

Effect on devolved taxes

Further devolvement of tax-raising powers could be announced. Speaking to AccountingWEB, RSM’s George Bull raised the potential devolvement of separate national insurance thresholds for Scottish taxpayers to allow for alignment with Scottish rate of income tax bands. As it is the class 1 NI threshold in Scotland is out of line with the 40% band, and the four alternatives for Scottish income tax could create even more confusion.


What would you like to see Philip Hammond propose next Wednesday? And what do you think will actually happen? 

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About Tom Herbert

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15th Nov 2017 10:04

I would like to see Hammond make a frank statement about what Brexit is going to cost the country, and how much money is needed to pay for what Leave promised, eg £350m/ week for the NHS plus the investment required in infrastructure, and education.
To raise required funding he will have to increase taxes and/or remove tax reliefs. I suggest:
1. Increase corporation tax to say 22%
2. Remove entrepreneurs' and investors' relief
3. Cap PPR or remove and replace with a roll-over relief
4. Align NI rates for employed and self-employed
5. Increase dividend tax
6. Introduce a statutory test for self-employment - like the SRT.
7. Reform council tax to increase number of upper bands and revalue all residential properties
8. Reform SDLT to make it easier for people to down size, perhaps make the seller pay not the buyer.

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to Rebecca Cave
15th Nov 2017 10:27

I would like to see Hammond be positive about Brexit and announce measures to make the UK an increasingly attractive place for people to do business and atttact inward investment in a post Brexit world.

1. Reduce corporation tax to 15% with a view to getting it down to 12.5% (if it works for the Irish....) - as Dyson said at the weekend "why would you want to tax profits? Profits should be re-invested".
2. Retain Entrepreneurs Relief and Investors Relief as they stand (to curb or abolish is to send an anti-business message)
3. Leave PPR alone - an English person's home is his / her castle.
4. Leave the current difference between employed and self-employed people.
5. Increase dividend tax, but only if corporation tax is reduced (ie: preference towards taxing people's income as opposed to business profits).
6. I agree with a statutory test for the self-employed to reduce uncertainty (as long as the legislation is not a dog's breakfast like the SRT)
7. Retain EIS, SEIS and VCT reliefs but tweak the rules to make sure valuable tax reliefs cannot apply for 'soft low risk' investment.
8. Accept that the Government have done a cracking job on tax avoidance, move on and focus on evasion. Staff up HMRC so there is the quantity and quality of people resource to sift through all of the information Connect provides and any access given to the Panama / Paradise papers.

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By catlady
to Rebecca Cave
15th Nov 2017 10:50

Yes, the council tax bands really need to be revised.

I live in in the Chilterns and a 4 bed house in my village (Band G) pays £2,817 pa. The sprawling estate down the road (Band H - the highest possible) pays £3,380 pa. Recent planning permission documentation shows that the house is able to accommodate up to 60 people when the complete extended family and staff visit! It is ridiculous to tax a five bed house the same as a 27 bed mansion!

(Maybe I am biased - the council have refused to fix the pot holes opposite my house as they are not deep enough yet!)

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to Rebecca Cave
15th Nov 2017 11:08

Measures to bring us another reccession, Reecca. Small business is on thin ice at present. Your measures will just crack that ice.

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to Rebecca Cave
15th Nov 2017 14:45

Thank you Rebecca for a simple set of suggestions.

1. Raise CT. Sounds sensible, the rate is probably now too low. This does connect with dividend tax of course.
2. Removing ER will cause shock horror but the CGT rates are now low. Is ER really the reason people go into business?
3. Capping PPR will be fun to get through Parliament.
4. Aligning NI rates will upset Ian D-S and his white van man. Arguments against it are a bit feeble.
5. Increasing dividend tax. Why impose a general extra tax on income of this sort only? What about property income and interest? Possibly raise it on 'close company' dividends only as this was surely intended to counter the NIC savings for such companies.
6. A statutory test for self-employment would be interesting as the details of it might well be fitted up by HMRC/Phil if noone is paying attention.
7. Charge more Council Tax to valuable houses. At what level should this kick in? Basically soak the rich and, I suppose, why not? Becomes then increasingly a property tax rather than a council services tax.
8. Reform of SDLT. The whole thing has just been done over and it is pretty complicated. For heavens sake leave it be. Some of the more awful complications of it might be removed.

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to Rebecca Cave
15th Nov 2017 14:49

3. This would be a passport to leaving office, if you are a minority government with a deal with A N Other that would be a very brave step (Translated by Sir Humphrey- foolish beyond belief)

I actually from a purist view do not object to it, it seems mad that we are taxed on income and gains re everything else but not our homes (if we do have to be taxed), and it could have a reinvestment rollover (akin to sweden) so really only bites when down sizing.

But it is political re generation rent and is not going to happen until the votes to be lost from those impacted is made up by the votes to be gained by those who think they gain.

I will also point out that it would be a behaviour changing policy, people would never downsize, availability of houses for sale would diminish. Right now I am thinking re next 2-3 years re a move, would like a bigger garden, garage, maybe more rural rather than North Edinburgh etc, bring that in and my current Edinburgh property will remain mine, we will not bother downsizing but will just sit tight, we have had the house for 20 years another twenty would beckon.

What I would maybe do is scrap IHT and bring in CGT on all latent gains upon death of the last survivor of a couple.

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to Rebecca Cave
15th Nov 2017 16:36

In other words hammer the self employed.

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to Rebecca Cave
16th Nov 2017 16:18

Why not also scrap VAT being charged between VAT registered businesses?

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to petestar1969
16th Nov 2017 16:34

Hey Pete, welcome to the club. VAT between two registered people in the EU doesn't have to be paid over. (I'm not talking about ABC).

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By ianmatt
15th Nov 2017 10:28

Not sure how Hammond can make a frank statement about future unknowns. What is certain is the NHS is a massive issue in terms of an ageing and increasing population.

Education is a disaster with such a huge drop out rate but Hammond like all politicians seem unable to sort out that mess, throwing more money at piecemeal improvements will only waste more taxpayers money.

With the national debt ever expanding and the politicians unable to sort out waste and poor management of resources in the Public Sector, Hammond will have to raise money. The mooted reduction in the VAT threshold would be a brave move. I can see both sides of that argument, it could kill some small traders but certainly reduce the huge abuse of the current rules.

If he does if it should be done properly, reducing to say £75000, won't have much impact on the current problems.

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to ianmatt
15th Nov 2017 11:11

There is only one way to reduce VAT threshold and that is to make evry business vatable anything else will enhance the "cliff edge".

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15th Nov 2017 11:00

Hammond is indeed caught between a rock and a hard place this year. The economy is in a rather fragile state and he won't want to cause economic stress but he needs to raise more cash to fund things like the NHS, because its troubles could be a big vote-loser.

Also, Brexit is bound to hit the economy in 2019, as trade with Europe declines and businesses look to other markets to compensate. This transition won't happen instantly so there will be a dip in performance, hopefully short term. This impact will be lessened if we don't go into Brexit with the economy already on a down-turn.

Hammond will also be under pressure not to do things which will need a lot of Parliamentary time next year, as parliament will be busy with Brexit-related legislation.

So expect tinkering at the edges, with changes to rates and thresholds mainly, not new initiatives.

The basic rate of Income tax is sacrosanct, but NI isn't, so he may increase employer rates a little, or raise the Upper Earnings Limit to increase the take from employees (even if this does break the link to the tax threshold).

VAT is the other 'biggie' in terms of tax collected, but an increase here would reduce consumer demand, and therefore dampen the economy, so I don't think this will happen.

Rates of duty on tobacco and alcohol may rise above inflation and I too would not be surprised to see a few pence on fuel duty this time around, as this has been left alone for a while.

SDLT is indeed seen as a barrier to young people entering the housing market, so there may be some reliefs here.

Tax relief on pension contributions certainly needs reform, but any major changes might be a step too far at present so again, expect tinkering with things like the Lifetime Allowance.

All-in-all, then, a fairly quiet budget would not surprise me at all!

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to neiltonks
15th Nov 2017 11:22

I have to agree that this will be either a non budget or very quiet. Unless he is going then he might set the cat amongst the pigeons.
I must take you up on the point that brexit will mean less trade with the EU. I don't think it will affect trade at all. Mercedes, VW, BMW, Bosch, Fiat et al are not going to cut their nose off to spite their face are they? We are in a very strong negotiating position and the EU are well aware, that's why they are stalling on talks over trade.

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to johnjenkins
15th Nov 2017 11:45

Of course, big companies like that are not going to stop trading with the UK. They trade all over the world and have the resources and experience to deal with whatever the inevitable changes in the trading environment are.

However there will be many smaller companies whose only experience of international trade so far has been within the EU, relatively free of bureaucracy. Regardless of how 'soft' or 'hard' Brexit turns out to be, there will inevitably be more bureaucracy around trade and travel than before. If there's not, we won't really have left. Smaller companies with no experience of international trade outside a free-trade area will inevitably find conditions become tougher and some will fail to cope, or simply decide it's more trouble than it's worth.

I'm not saying trade will collapse, but I believe there will be a dip immediately after Brexit, while everyone adjusts to the new environment.

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to neiltonks
15th Nov 2017 11:55

I understand your reasoning but this a small world now. The young small traders are on top of where and when. Don't get me wrong it's not going to be easypeasy. Let's face it if North Korea, with all the sanctions against it, can still survive then we will be in paradise once the chains are unlocked. So let's leave today and get this ball rolling.

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to johnjenkins
15th Nov 2017 15:15

Depends on the terms we get, tariffs will likely reduce trade.

If I am a car maker in EU and the cost to my UK purchaser increases as he needs to pay x on top of previous price the UK demand will decrease, remember all these lovely supply and demand curves in microeconomics 101. In addition if I am an EU citizen who previously would have bought a UK made car, it now costs me more re the tariff I need to pay, so maybe I just buy the EU built one instead. (Of course same for us-we then buy those made here, if re parts and components they can still be made here)

Of course exchange rates will muddy the water, we have already seen this in part but I expect more volatility as the likely deal becomes more apparent.

But notwithstanding above the real killer is parts/components/dealer networks and conformity, this is possibly going to be a real issue without a deal. (as is financial service regulation)

Now some of the Far East manufacturers get past these issues as they have far lower labour costs and can absorb the friction costs, but EU to UK and UK to EU standards of living are far more similar, the cheap labour edge is just not there, for either. (No comparative advantage with labour costs)

Any study of economic history is going to show that whilst short term advantage may come from tariffs long term this is really not the case, so your confidence in a no problem deal needs to be right, because if not things are going to get very, very, messy.

Brexit is a gamble right now and the A Team in charge do not fill me with confidence.

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15th Nov 2017 15:38

I think the problem lies with "no confidence" in our future. Shucks a future without the EU telling us what to do and how and when to do it. I think the reverse. It is the EU who are behind the times and need to get "on board" or they will feel the pinch. They are an inflexible lot and with technology screaming ahead you need to be as flexible as possible. That doesn't mean we don't have stability. The balance has to be right and it's up to us to show that we can do it. Look at our football team. We only need a midfield playmaker and we are there. I'm sure our brexit team want to say "if you don't want to talk about trade there is no point in anymore discussions". Let's have a look at what has changed mmmmmmmmmmmm nothing. Oh yes we don't want access to single market linked with the non flexible approach to people movement. Is that really that wrong?

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to johnjenkins
15th Nov 2017 16:29

No, my no confidence is squarely aimed at our Dream Team in the negotiations, but you never know, maybe by March 18 (because that is probably how long we have to get an outline established re what may happen before bad things start happening) we will actually "know" something beyond , we are leaving.

And frankly your appraisal re your football team is also over optimistic, you are short of far more than a midfielder. ( And forget the friendlies, they do not count, your defence is not top rate, it is second tier), inability to control games tends to see them lost, and you in no way controlled anything last night.

The trouble is you have not had enough let downs to appreciate the limitations, if you had supported Scotland
since 1978 (well actually before, but 1978 was the pinnancle re national self delusion) you would have a far better appreciation that what can go wrong will go wrong and a bit less belief that "we are nearly the finished product. "

Prediction- quarter finals is best you manage, much better than us but still falling short of where a country with your resources/population ought to be aiming.

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15th Nov 2017 16:47

It wasn't you that broke the crossbar was it????????? I really believe that with a "playmaker" we can go all the way. If we don't get one then I'll have to agree with you.
Hoping to get up to Aviemore for new year. Love the steak pie.

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to johnjenkins
15th Nov 2017 18:15

No, in 1977 I was fairly thin, I could certainly break a crossbar nowadays.

The day after that game there were fans with carrier bags of turf staggering around Lothian Road in Edinburgh, I recall being in a queue ,in I think KFC ,with some guy just standing and swaying back and forward whilst showing everyone "his " turf.

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16th Nov 2017 08:36

Just as well e-bay wasn't about then.

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to johnjenkins
16th Nov 2017 14:41

There were sales of "grass" post the game; pretty sure a fair bit of it originated from back gardens (certificates of authenticity not being available), we Scots are an enterprising lot.

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16th Nov 2017 16:32

I thought it was mostly resin in the 70's.

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to johnjenkins
16th Nov 2017 19:00

I couldn't possibly comment.

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to neiltonks
15th Nov 2017 11:23

I'm inclined to agree with your quiet Budget assessment.

The other factor I didn't have space to include in my piece was Parliamentary time. With bucketloads of Brexit legislation to get through in the next year and a half, any major tax/business legislation overhaul just isn't going to get the necessary oversight.

However, I do have a sneaking suspicious Mr Hammond has a surprise or two waiting for us, particularly as very little has leaked out of Downing Street.

The timing of the OTS VAT report was convenient as a quasi-policy kite to test public reaction - what the government has made of the feedback will be interesting.

Or perhaps it'll finally be the year for income tax and NI?? Or maybe not...

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By vowlesj
15th Nov 2017 11:50

governments need tax, this government could do with more. but hitting entrepreneurs is often counterproductive. entrepreneurs build businesses and employ people which is needed and should be looked after. Also corporation tax isn't a big hitter. Around 75% of all tax comes from income tax, nic and VAT. Therefore it makes sense to make changes where it makes the biggest difference. Increase the basic rate of tax or NIC and that will do it. Similarly drop the VAT threshold to say £10k and he will get a nice little earner. it was originally made high as complying with VAT was an administrative burden. Modern bookkeeping software means VAT isn't that much of a burden and therefore there is no reason to have a high threshold.

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15th Nov 2017 12:29

I have always been mystified as to why people think reducing SDLT will help any property buyer as there is inevitably a correlation between SDLT going down and property prices going up (and vice versa), so the net effect should be near to zero (all else being equal). (Just like I read in the papers recently that there is a very strong correlation between mortgage interest and property prices - which is unsurprising as a rental property at least is more or less like a bond re interest rate changes all else being equal.)

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15th Nov 2017 12:37

Corporation tax is just a cost of doing buiness just like staff costs. As others have said after Brexit reduce it to 10%, but alongside increase the income tax charge on dividends. What this means is that those businesses who invest have more to invest and will employ more who pay VAT, income and NIC.

According to the statement attached to my wifes tax coding 33% of the tax and NIC paid is on benefits ignoring state pension.

Thus the more who work should mean a reduction in this figure. As many do I ask the question is our system too generous. I was told that in Spain and France the payments dont go on for ever but are restricted. Whilst a red hot potatoe for any Chancellor this area should at least not be avoided.

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to pauljohnston
15th Nov 2017 13:25

That's a red hot spelling error (I thought Dan Quayle's famous misspelling of potato had put a stop to that).

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to Justin Bryant
15th Nov 2017 13:51

There's me thinking that only chillie peppers were red hot.

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By Tobby
16th Nov 2017 12:06

I believe Hammond has an easy way to tax the avoidance of the large multi national companies which deflect profits into tax havens.
Abolish loss relief and the use of transfer pricing costs for these companies where the mechanisms are clearly artificial.
Even better though would be to exempt these companies from corporation tax altogether and tax their UK turnover. It is infinitely more difficult to shelter turnover.
At a stroke Hammond would create a massive windfall by taxing, say 4%, of turnover and collect the cash quarterly.

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By Mikolaj
15th Nov 2017 19:22

Rebecca I am aghast at your comments.
Firstly no one has any idea what Brexit will cost, so asking for estimates would be ridiculous. All predictions to date have been spurious and very wide of the mark, from both camps!
Also, to increase taxes generally means that the total tax take falls, most economic evidence substantiates this in just about every economy in the world. Reducing taxes makes them more acceptable to one and all; more palatable one might say, so the total tax take of any nation increases when this such policies are pursued.

I am all for aligning NI and straighforward tax simplification but the OFTS has done diddly squat since its inception many moons ago. Boo to them, an utter waste of our taxes!

To conclude, opting for a high tax economy simply penalises our natural entrepreneurial spirit and history teaches us that such measures bring geven reater financial woes in the medium and long term. Socialism is never a cure merely a beautiful dillusion.

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17th Nov 2017 10:42

My observation from the front line, as it were, is that we are very close to a crisis.

The real cost of living is rising quickly. Wages are not. Housing costs are still way too high. Disposable income is not rising.

What I wish for is a chancellor brave enough to eschew the easy targets of regressive taxes - duty, IPT, VAT, etc. Almost every regular "tool" in the chancellor's "toolbox" is regressive in nature.

As for increasing taxes on the self employed, why for heaven's sake? There is a perception that "white van man" somehow carries no risk and is "coining it" at the expense of the hard-working employees. Balderdash!

Accountants may feel that their trades carry little risk (there will always be those who need them), but in most businesses this is just not true. We need a thriving entrepreneurial spirit or - quite frankly - we are done-for; something is going to have to help fix the terrible productivity in the UK, and it won't be multinationals hiring minimum-wage workers.

And what else? Business rates. If we ignore the calls to scrap it completely for a moment, can we at least level it out so that areas are averaged? Why should offices pay so much less than shops, for instance? Surely the "knowledge workers" should be more profitable these days? Small premises are always more expensive (psf) than large premises, but they are occupied by smaller businesses (and the small business relief is of very little benefit) - so let's even that out, too. And mail order warehouses are just as big a retail player as shops now.

So what I propose is a flat "zone" business rate psf - every business in a given area pays the same psf.

Anyhow, I doubt any of this will come to pass - instead the chancellor will fiddle with the regressive elements once again and ignore the bigger issues facing the country.

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to skwdenyer
17th Nov 2017 15:50

"Crisis what crisis"? No three day week. Credit card limits rising. Uber charging £7 for a 2 mile journey at 2 am. William and Harry and Bond in "star wars". Boris and Trump taking over Zimbabwe (not really a coup) Big Ben allowed to strike new year in. Robots doing back flips. Jo Brand having a pop a Hislop. Hollywood doing a film about Pestminster starring Sly and Spacey featuring spreadsheet Phil fiddling with regressive elements.
Well it is Friday PM.

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