Pearse Trust Blog

Patent Box Regimes are deliberate government tax policies designed to encourage and promote innovation by providing tax concessions on worldwide income attributable to certain types of Intellectual Property (“IP”), subject to particular conditions.

The purpose of this blog is to provide a summary of the UK corporation tax return filing dates and due dates related to the payment of corporation tax.

Filing Dates

A UK tax resident company is required to file a corporation tax return (CT600) for each Chargeable Accounting Period (“CAP”). There are detailed rules to determine the commencement and end of a chargeable accounting period.

There have been continuous improvements to Ireland’s Research and Development (“R&D”) Tax Credit since its introduction in 2004.

The 2015 Budget also made a major amendment to the R&D Tax Credit. The 2003 “base year” will be removed entirely from 1 January 2015.

The Tax Foundation recently published its international tax competitiveness index (“ITCI”) which has ranked New Zealand as having the second most competitive tax system out of 34 OECD countries.

The UK ‘Office of Tax Simplification’ (“OTS”) has recently published a review into the competitiveness of the UK’s tax administration.

The review involved the OTS speaking to a variety of interested parties including, amongst others, small and large businesses, tax advisors and various representative bodies.

Background

The brief behind this review was to examine how to improve the competitiveness of the UK’s tax administration, with particular regard to the 2014 World Bank’s ‘Paying Taxes’ report.

Prime Minister John Key's National Party have won a third term, narrowly missing out on an unprecedented govern-alone victory. The re-elected national Government has pledged to return to surplus this financial year and stay there in order to reduce debt, lower ACC levies and start modestly reducing income taxes.

Voting System

New Zealand uses the Mixed Member Proportional (“MMP”) voting system, giving voters two votes; one for a political party and one for their local electorate MP. The party vote decides how many seats each party gets in the new Parliament; a party is entitled to a share of the seats if it receives 5% of the party vote or wins an electorate.

The central-right National Party won 47% of the vote, giving the party 60 of the 121 available parliamentary seats.

On 14 October 2014, the Minister for Finance Michael Noonan, delivered Ireland’s Budget for 2015. As part of the Budget package, the Minister also published a Road Map “to secure Ireland’s place as the destination for the best and most successful companies in the world”.

The favourable provisions introduced in the Budget increase the attractiveness of Ireland as a location to carry on business and also improve the transparency of Ireland’s tax regime.

A summary of the advantageous measures incorporated in the Budget are as follows:

In what appears to be the first challenge to the US Foreign Account Tax Compliance Act (“FATCA”), lawyers for Gwen Deegan of Toronto and Virginia Hillis of Windsor, Ontario say that FATCA exposes their clients 'to a deprivation of their liberty and security of the persons', in violation of Canadian Constitutional rights. FATCA applies to all “US persons”, which in itself is an expansive test and captures many groups of people that may not even realise they are “US persons".

The Organisation for Economic Co-Operation and Development (the “OECD”) has introduced new country-by-country reporting recommendations which provide for multinationals to disclose a breakdown of all countries in which their profits are made, where their taxes are paid and whether they are shifted elsewhere.

Further to our previous blog on FATCA wherein we observed the postponement of the implementation dates for FATCA, the regime has now been implemented since July 2014.

Jurisdictions across the world are producing local legislation and guidance in order to implement FATCA on their home soil.