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PETE MILLER suggests that there has been a change of approach to the associated companies rules and the small profits rate
KEY POINTS
- The background to the associated companies rules.
- The unfairness of the mechanistic approach.
- What happened to the requirement for relevant tax planning arrangements?
- It is planned that the legislative proposals are to be changed to match the HMRC guidance.
- Should we return to the original plan?
Following a consultation process that ended in February this year HM Treasury and HMRC have published a response document: Simplification review: the associated company rules as they apply to the small profits rate of corporation tax – a summary of consultation responses. 
Despite not being officially a consultation document comments are invited (albeit without a time limit as yet) and the document has new draft legislation that is completely different from...
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