This Pre-Budget Report will be all about the long-term. The Chancellor will want to reassure us that the election will be just a blip on his economic calendar and that his plans for the tax system will continue unabated.
We can, therefore, expect a number of consultation documents outlining proposals for future changes to the tax regime.
The Chancellor has already promised to publish a discussion paper on the taxation of small owner-managed businesses with proposals to “ensure that the tax system reflects the realities of today’s changing labour market and business environment.
He may also take this opportunity to put on a firmer footing the application of the settlements legislation to owners of small family companies whose spouse receives a dividend.
We can also expect the next stage of the debate over the introduction of property investment funds which should include more detail on the proposed regime, albeit deferring implementation until after the election.
The conclusion of the reform of corporation tax debate is now long overdue and the Chancellor could use the Pre-Budget Report to start tying up some of the loose ends. These include the reform of the schedular system, bringing the taxation of capital assets more in line with the accounting treatment and a further debate on the possibility of replacing the capital allowances system with relief for commercial depreciation.
For individuals, there is a chance that the Chancellor will end the recent speculation over the taxation of individuals who continue to benefit from free or low-cost enjoyment of assets they formerly owned, by clarifying the operational aspects of the new regime.
The consultation on the modernisation of the taxation of UK resident trusts ended on 5 November so it is likely that the next stage of this debate will also be announced.
Finally, the debate over the tax rules relating to domicile and residence rumbles on and, while the Chancellor is unlikely to conclude it in his Pre-Budget Report, he is equally unlikely to let the matter drop altogether.
This is not going to be a controversial Pre-Budget Report but, at the same time, the Chancellor is not going to let it pass without taking the chance to continue to advance his policies. Despite the forthcoming election, this Pre-Budget Report is going to be very much business as usual.
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