Part V: Corporation Tax

1. Is it obvious that companies should be taxed on their profits?

2. Explain the options available to address economic double taxation of companies and shareholders.

3. Are tax benefits for small businesses such as a reduced rate of corporation tax on ‘small profits’ good tax policy?

4. How and why is debt treated more favourably than equity for tax purposes, and what reform options are available to more closely align the tax treatment of debt and equity?

5. What are the meanings of ‘ordinary share capital’ and ‘beneficial ownership’ in the context of corporation tax, and why are they important?

6. What is a ‘distribution’? In what circumstances are interest payments treated as distribution, and is this sensible?

7. What are ‘loan relationships’? Is the extensive reliance on accounting in this regime and similar regimes including for derivates appropriate?

8. What is the ‘substantial shareholding exemption’ and is it overly generous?

9. How freely should it be possible for companies to set losses against profits to reduce tax payable? Are limits on deducting carryforward losses appropriate?

10. To what extent should losses from one activity be allowable against profits of another?

11. Should there be a time limit on carrying losses forward and back?

12. Should the losses of one taxpayer be available against the profits of another (i.e. should losses be freely transferable?).

13. Should a group of companies be treated as one tax unit for tax purposes?

14. How does the UK define a ‘group’ for trading profits/losses and capital gains tax purposes, and why are the definitions different?

15. How do tax losses work within a corporate group? What happens if the group companies are in different jurisdictions?

16. What is a ‘close company’ and why are special rules for close companies necessary?

17. Are special anti-avoidance rules for companies, shares and bonds necessary or is the GAAR sufficient?