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KEITH M GORDON MA (Oxon), ACA, CTA, barrister considers the practical issues facing companies in the light of non-corporate distribution rate legislation.
FEW READERS CAN honestly believe that the non-corporate distribution rate rules represent the best of recent tax policy. First, they were introduced in a rush; secondly, they introduced a large amount of unnecessary complexity; thirdly, but for the complexity, their overall effect is more or less akin to the repeal of the corporation tax starting rate.
KEITH M GORDON MA (Oxon) ACA CTA barrister considers the practical issues facing companies in the light of non-corporate distribution rate legislation.
FEW READERS CAN honestly believe that the non-corporate distribution rate rules represent the best of recent tax policy. First they were introduced in a rush; secondly they introduced a large amount of unnecessary complexity; thirdly but for the complexity their overall effect is more or less akin to the repeal of the corporation tax starting rate.
In my articles 'That Gift Horse again' Taxation 3 February 2005 page 426 and 'Careless drafting costs tax' Corporate Tax Review 2005 4(2) 21-33 I suggested that the provisions had a wider scope than the Inland Revenue had previously claimed. Adopting the former Revenue line would have allowed companies to drive a coach and horses through the provisions...
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