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Autumn Statement: Taxman to shut three corporation tax loopholes
by Jun Merrett on Dec 05, 2012 at 15:22
The government has moved to shut down three loopholes used by companies to avoid paying corporation tax.
HM Revenue & Customs (HMRC) has introduced a measure which will block schemes based on partnership, set up to avoid existing mismatch legislation.
Mismatch legislation exists to stop companies gaining a tax benefit though a group-owned scheme making a loss.
The measure also aims to block schemes which exploit property total return swaps legislation, and schemes involved in manufactured payments and loan write-offs.
The government has also introduced legislation to abolish income tax relief for patent royalties.
Currently patent royalties are relievable against other income from the same year, but only for royalties not deducted in calculating income tax liability.
The government is proposing to add legislation in the Financial Bill 2013 to amend a section of the Income Tax Act to eradicate the relief.
The measure is also intended to crack down on tax avoidance arrangements that exploit the relief.
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