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News : UK Economy Last Updated: Feb 20, 2013 - 12:53 PM


UK new scourge of tax havens, favourite tax location for big business
By Finfacts Team
Feb 20, 2013 - 8:27 AM

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As the UK leads a campaign for action against corporate tax avoidance and seriously trims the sails of domestic offshore tax havens, it has overtaken low-tax rivals such as Ireland, Luxembourg and Switzerland, to become big multinationals’ favourite tax regime.

It may be just a survey but George Osborne, chancellor of the exchequer, hailed it as a “remarkable turnaround” in efforts to make the country more attractive to foreign investors. However, the debate over corporate tax avoidance is making business jittery, with 63% of big companies polled by KPMG, professional services group, saying it had adversely affected UK tax competitiveness.

The UK is now the most attractive tax regime compared to key competitors, according to KPMG’s sixth Annual Survey of Tax Competitiveness [pdf] - -  the results were published this week.

For KPMG’s 2012 Tax Competiveness Survey, senior tax  professionals from some of the UK’s largest companies were  interviewed by specialist strategy consultants, Gulland Padfield, on which countries they thought were the most attractive from  a tax perspective. For the first time in the survey’s history, the UK came first in terms of most commonly cited in the top  three.

Osborne has cut the headline rate of corporation tax from 28% in 2008 to a planned 22% rate in 2014.

Researchers polled executives at 57 international companies - -  both British-owned and foreign -- and asked which countries had the lowest tax burden. Some 72% of the executives questioned named Britain as among the most tax-competitive countries, up from 27% last year. The UK finished fifth in the annual survey last year.

Domestic tax havens

UK tax officials are to be given the names behind secret offshore bank accounts held in the Isle of Man as part of a new crackdown on tax havens.

A similar deal granting Revenue & Customs inspectors access to accounts in Jersey and Guernsey is also due to be agreed.

The maximum income tax rate in the Isle of man is 20% (compared with 45% in Britain from April 2013). There is also a generous tax-free allowance and a big chunk of income is taxed at just 10%.

The agreement includes a “disclosure facility” to allow account-holders on the island to come forward and settle outstanding tax bills, plus interest, before their details are passed to HM Revenue & Customs.

The Financial Times says the disclosure facility is expected to start on April 6 and run until September 2016. It will not be open to individuals already under investigation but will cover liabilities dating back to April 1999. The facility offers immunity from prosecution but, in most cases there will be a penalty charge of 10% of unpaid tax up to 2009 and 20% for later years. Those who do not come forward could be hit by a penalty of up to 200% of the unpaid tax, or prosecution.

The Treasury said the deal was modelled on an agreement with the US to improve international tax compliance – the Foreign Account Tax Compliance Act (Fatca). The UK and Isle of Man’s version of Facta will, like the US rules, allow for the sharing of information across borders.

The UK has also set up disclosure facilities with Liechtenstein and Switzerland and it expects to collect billions from untaxed revenues in coming years.

Andrew Watters, director and tax specialist at Thomas Eggar LLP, a national UK law firm, commented today: “The announcement is simply the latest example of the ongoing determination of the UK authorities, in collaboration with the Organisation for Economic Co-operation and Development (OECD), to ensure they know about assets held abroad by UK residents. The Channel Islands, together with various other international financial centres, are under similar pressure. Having identified the persons concerned, the taxman will examine their affairs to see whether there is avoidance or evasion.
 
“Individuals who hold such offshore assets may wish to consider whether they are exposed to challenge. Some, including non-domiciled individuals, may have an over-optimistic view of their tax position. If there is an undisclosed liability, there are opportunities to gain advantageous terms by making a voluntary disclosure.
 
“The reference to having until 2016 to make a disclosure clearly links to the terms of the Liechtenstein Disclosure Facility which is open until 2016. However, for anyone who is thinking of waiting, the danger is that if their name comes to the attention of the UK authorities before they make a voluntary disclosure, then the option of such a disclosure disappears and they can face substantial civil penalties or even criminal prosecution.”

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