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Last Updated: Monday, 5 December 2005, 18:19 GMT
Plenty of pre-Budget detail to unpick
By John Whiting
Tax partner at PricewaterhouseCoopers

John Whiting
John Whiting: Good news on property investment trusts
Unsurprisingly, Chancellor Gordon Brown made much in the pre-Budget report of his extra help for families through tax credits.

More money is flowing into all elements - Working and Child Tax Credits - from next April, with the exception of the 545 annual "family element", claimed by those on incomes up to 58,500.

But the key change is that the extra income that claimants can earn in a year before suffering a clawback of credits is being raised dramatically from 2,500 to 25,000 from next April.

This sounds a technical measure but it will reduce significantly the numbers of people faced with a demand for repayment of what turn out to be tax credit overpayments (and help HM Revenue & Customs administration).

There will also be new rules phasing repayments for those facing a clawback.


It had been expected that property measures would feature strongly in the speech. In the event, two dogs barked and one (unsurprisingly) didn't.

One of the woofs came in the wake of the Barker report with the announcement of consultations into a "Local Planning Gain supplement" (LPGS).

The idea is to raise more tax when planning permission is granted: the theory is easy to see but the risk is that developers (who would pay tax in any event) will hold back development rather than release land.

There was no move on alleviating the Inheritance Tax burden on families due to higher house prices

However, the talk of "local" here does at least sound as if one concern has been met - monies raised through the LPGS will be raised from local planning consents and used for local projects.

A more positive move was the commitment to go ahead with REITs - Real Estate Investment Trusts.

Discussions have been under way for some time on this unit trust-style property investment vehicle and it is good news to hear they are definitely to be introduced.

REITs will operate as stock exchange-quoted companies which directly own property, providing an easier and lower-cost way for people to invest in a range of real estate such as shopping centres, cinema and residential property.

The dog that didn't bark was any sort of move on alleviating the Inheritance Tax burden on families, due in the main to higher house prices.

Many have been hoping that there would be some action here but in reality this was unlikely: IHT was probably "done" in the March Budget when modest rises in the main threshold were announced for the next couple of years.


It was only to be expected that there would be more blocking of avoidance schemes in the wake of the tax avoidance disclosure regime introduced last year. In many ways, the flow of changes is a sign that the disclosure regime is working.

The announcement of changes to the disclosure regime does raise some concerns.

The "filters" are going to be refined and in-house schemes will have to be disclosed within 30 days.

An enterprise theme was expected and to a degree we got it

The acid test of all this is not that there is to be more disclosure - none of us operate on anything other than full disclosure - but will this mean more detailed disclosures of routine planning, to nobody's real advantage?

One curious announcement in Gordon Brown's anti-avoidance section was the suggestion of restrictions on Self Invested Personal Pensions (SIPPs) investments to prohibit "obtaining tax advantages on residential property, fine wines and certain other assets".

How exactly this will work is one to study carefully between now and 'A Day' (6 April 2006).

But it seems to prevent all investment through a SIPP in residential property.

Business measures

An enterprise theme was expected and to a degree we got it.

We heard about improvements to the Research and Development tax credit regime last week and this was reiterated, together with more skills-building measures.

The 0% corporation tax starter rate for companies with under 10,000 of profits is to go with compensation via higher capital allowances.

The introduction of this lower rate has not been a happy one with many pointing out when it was introduced that it would simply drive people to incorporate.

That led to the "Non Corporate Distribution rate" to tax those who drew dividends.

Now we seem to be going back to where we were, with small businesses probably wanting to be left alone rather than suffer more changes like this episode.

The elderly will raise a modest cheer for the way the winter fuel allowances have been made permanent at 200

Oil companies will be disappointed with the extra levy on their North Sea profits, with the doubling of the supplementary petroleum duty to 20%.

But perhaps the promise of further incentives for new exploration is some compensation.

Headlines: Tax increases or reductions?

At the end of the day, most people will look to a statement such as the PBR to see if they are better or worse off.

The answer here is: probably not much change.


We heard about the basic tax allowances for 2005/06 - all raised by about 2.8% in line with inflation (though fiscal drag means that there is in some way a small tax increase with these modest rises).

There were no changes to the "sin" taxes - smoking, drinking or driving (as the petrol and diesel duties were frozen).

The elderly will raise a modest cheer for the way the winter fuel allowances have been made permanent at 200 (300 for those aged over 80).

The idea of using monies from dormant bank accounts for community projects - sporting and similar - is a neat way forward.

Overall, as always, the chancellor packed a lot into his 35 minute speech but as is so often the case, many of the announcements relate to the future - there are plenty of things, including the usual Brownian fine print, to look forward to.

Watch the Chancellor's pre-Budget report

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