Anti-avoidance measures |
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An increasing theme for both main Budgets and Pre-Budget Reports has been the introduction of targeted anti-avoidance rules. This year’s PBR is no different:
Risk transfer schemes
Measures will be introduced with effect from 1 April 2010 to restrict loss
relief on certain group hedging transactions such that losses are limited to
the real economic losses suffered by the group concerned, are ring fenced, and
can only be offset against profits from the same arrangements.
Insurance premium tax
New measures will be introduced with effect from 9 December 2009 to prevent the
avoidance of insurance premium tax (IPT) on insurance provided to individuals,
by splitting the premium between two contracts, one being predominantly for the
administration charges (which would not attract IPT).
Other specific anti-avoidance measures have been introduced targeted at inheritance tax, index linked gilt-edged securities, stamp duty land tax and sale of lessor companies to name a few.
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