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Against a backdrop of fiscal constraint and significant economic uncertainty following Britain’s vote to leave the EU, Philip Hammond has today delivered his first (and last, but more about that later) Autumn Statement following his appointment as Chancellor in July this year.
The UK government’s decision to focus on infrastructure spending to boost productivity and promote growth in Northern Ireland saw the Chancellor announce an additional £250M (over the next four years) to the Northern Ireland Executive’s budget for such projects. This was welcome news particularly in light of lower growth forecasts largely driven by the Brexit uncertainty.
However, how do the other detailed announcements impact upon the local economy?
Certainty and stability for business
The Chancellor acknowledged that certainty and stability are highly valued by business and looked to create this by confirming the government’s commitment to the business tax road map issued at Budget in March this year. This means that the main rate of corporation tax will fall to 17% by 2020 and the business rates reduction package will be implemented.
Many had predicted the Chancellor would announce further reductions to corporation tax, however the fact that this did not materialise means that the introduction of a 12.5% rate of corporation tax in Northern Ireland may still be seen by many to be a differentiator which could drive additional investment.
Within the fine detail, the government has announced that it will amend the Northern Ireland Corporation Tax regime in Finance Bill 2017, to give all small and medium sized enterprises (SMEs) trading in Northern Ireland the potential to benefit.
The government confirmed it continues to work closely with the Executive towards the introduction of this lower rate. The onus now lies with the Executive to agree the impact on the block grant and demonstrate sustainable budgets to Treasury. The needs to happen as soon as possible to provide local business and potential investors certainty to make decisions.
Companies owned by certain institutional investors
In addition, and following consultation over the summer, the government will make changes to the substantial shareholding exemption to simplify the rules by relaxing the investor requirement thereby providing a more comprehensive exemption for companies owned by certain institutional investors with effect from April 2017.
Recognising the public concern that the tax system is pitched in favour of large multinational groups, the Chancellor also confirmed that the plans to restrict tax relief for corporate interest expense and reforms of the way that tax relief is provided for historic losses will be implemented. However, the inclusion of ‘de minimis’ levels should result in the majority of Northern Ireland business seeing no change.
While the apparent commitment to provide certainty and stability is to be welcomed, we believe this was a missed opportunity for wholesale simplification and reform of the UK tax system. The UK has one of the most complex tax regimes in the world. This needs to be addressed so that we have a tax regime fit for a digital age which helps to support an economy focussed on high productivity.
The Chancellor did announce a reform of the Budget process, moving the main fiscal event to the Autumn from 2017 and making a commitment to limit tax changes to this main event unless extenuating circumstances arise. This is welcome news as it allows more time for parliamentary debate and scrutiny of the measures announced before they become law.
A fair sacrifice?
Successive governments have expressed concern about the cost to the Exchequer from the use of arrangements where employees give up an amount of cash salary for one or more benefits that may be subject to less tax and/or NIC (often known as salary sacrifice arrangements).
The Chancellor referred today to these arrangements being unfair and said that employees will pay the same tax under salary sacrifice arrangements as everyone else from April 2017. However, the Chancellor said that in response to consultations with stakeholders the new rules will not apply where the salary sacrifice is for an ultra-low emission vehicle (ULEV), pensions saving, childcare and the cycle to work scheme. To ease the impact on employees who currently have car, accommodation and school fees benefits under a salary sacrifice arrangement, which was in place before April 2017, those arrangements will be protected until April 2021. Other arrangements in place before April 2017 will be protected until April 2018.
A system that works for everyone?
Despite economic uncertainty, the Chancellor today confirmed the Government's commitment to raise the income tax personal allowance to £12,500 and the threshold at which higher rate tax applies to £50,000 by the end of this Parliament in 2020. These figures represent significant real terms increases in post-tax income for all individuals whose income is likely to exceed £12,500 by that time. We are pleased that the Chancellor has followed through on this promise made by his predecessor to support the aspirations of lower and middle earners.
Two new income tax allowances will be created for trading and property income, whereby individuals with either type of income below the level of the allowance (£1,000) will no longer need to declare or pay tax on that income.
Taxation of individuals
The Autumn Statement reconfirms the proposed reforms to the taxation of individuals domiciled outside of the UK (non-doms) from April 2017. Non-doms have previously been able to pay tax on foreign income and gains only to the extent they were brought to the UK, and have also been able to mitigate inheritance tax on their assets in some circumstances.
The reforms propose that non-doms will be treated as UK domiciled for all tax purposes once they have been resident here for 15 of the last 20 tax years, such that they will pay tax on worldwide income and gains irrespective of whether the funds are brought to the UK. There are related changes ensuring that inheritance tax is payable on UK residential property owned by non-doms.
The Government is walking a tightrope here with the aim of both ensuring fairness in the tax system and encouraging wealthy non-doms to remain in the UK. A major part of this balancing act will be the treatment of offshore trusts established by non-doms before the new rules come into effect, as the majority of the wealth of non-dom families is often held in such structures.
The Autumn Statement policy paper promises that foreign income and gains retained in such trusts will not be taxed, but there is much detail still to be considered. It will be impossible to judge how successful the Chancellor has been in achieving his aims until the rules have been digested.
Other measures directly benefitting Northern Ireland
- fuel duty is frozen which should save the average car driver in Northern Ireland £10 each time they fill their tank;
- Northern Ireland’s universities should benefit from the increase in funding for research and innovation by £2billion a year by 2020-21; and
- further investments in digital infrastructure such as fibre broadband and 5G will ensure that businesses in Northern Ireland are well placed to take advantage of the opportunities presented by new technologies and can reap the benefits of greater connectivity.
Addressing avoidance
While no detail has been announced, the Chancellor noted that more businesses are being incorporated and this is reducing the tax revenues generated from those businesses. This is to be expected where corporation tax rates are so much lower than tax rates for individuals. It is possible that we may some changes in this area in subsequent budgets.