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From 1 April 2023, the main rate of UK corporation tax will increase from 19% to 25%, signalling the end of the current one-size-fits-all approach.
A small profits rate of 19% will apply to augmented profits below the lower limit of £50,000. Profits exceeding the upper limit of £250,000 will be charged at 25%. Marginal relief will be available for profits falling between the lower and upper limits.
HM Treasury estimates that around 70% of UK companies will continue to pay tax at 19% with 10% of companies paying the new 25% rate.
An important point is the change from the related company test to the associated company rules. This change may effect payment dates and a company’s classification for quarterly instalment payment purposes.
Fortunately, there is still time to plan ahead and potentially mitigate the negative impact forecasted.
If a company is making tax losses, consideration should be given to whether it would be more beneficial to delay utilisation for use in future accounting periods.
It may be helpful to potentially accelerate any recognisable profits to pre-April 2023 and conversely delay expenditure to attain favourable tax rates.
Deferment of capital expenditure until post April 2023 at first glance appears attractive, with relief on purchases at the higher rate of 25%. However, companies will gain no real benefit from delaying essential capital expenditure due to the availability of the 130% ‘super-deduction’ introduced by the government and available until 31 March 2023. The ‘super-deduction’ ensures that the relief attained by companies (130% of 19% = 24.7%) is almost the same as the new headline rate of 25% which will broadly place them in a tax neutral position.
Now may also be an ideal time to review the number of companies under common control, with consideration given to how a restructuring exercise could deliver a more tax efficient group structure. Based on our recent experience, many corporate groups have already commenced projects to consolidate businesses, rationalise inter-company balances and strike-off dormant entities with a view to increased efficiency.
The clock is ticking on what will undoubtedly be challenging times for taxpayers but some simple measures in preparation can help limit tax exposure. Businesses benefiting from effective tax planning will be best placed to navigate the significant changes ahead.