If I had to sum up Budget 2024 for corporates in one word it would be 'boring'. And that is a good thing. By and large corporate tax directors like predictability and stability. Not the pantomime of recent years of corporation tax is going up (March, 2021); oh no it isn't (September, 2022); oh yes it is (November, 2022)!
That said, energy companies may be disappointed by the extension of the Energy Profits Levy to 31 March 2029 and the reform of the non-dom regime may have implications for groups with an internationally mobile workforce. On the subject of employees, combining the new UK ISA with a Sharesave or Save As You Earn scheme could provide employees with a very efficient way to invest in their London listed employer.
Then there are the consultations to keep an eye on. Groups disappointed when plant and machinery used for leasing was excluded from full expensing first time around will note the announcement that the government is seeking to extend full expensing to such plant and machinery 'when fiscal conditions allow' with draft legislation to be published shortly. At first blush, the announcement that the government intends to move to a residence based regime for inheritance tax might not appear to have that much relevance to companies. However, under the current 'situs' based system non-resident investors in listed UK plc's are often surprised to find they are within scope of UK inheritance tax simply because that is where the company's share register is maintained and a move to a residence based system would remove a potential disincentive for overseas investors in UK equities.
So overall a few bits and pieces here and there but a (welcome) 'as you were' for most corporates as the Chancellor focussed his attention – and chequebook – on individuals in the run up to the election.
This article was first published in the 8 March 2024 edition of Tax Journal.
