The Autumn Statement was delivered on 25 November 2015 and the following tax measures were announced:

Apprenticeships levy

With effect from April 2017 an Apprenticeships Levy will be introduced at a rate of 0.5% of total payroll and will be collected from employers through the PAYE system. Employers will however have an allowance of GBP 15,000 to offset the levy, so in practice the levy will only affect employers with payrolls above GBP 3 million per annum.

GAAR penalties

In the case of any tax due where a case has been challenged successfully under the general anti abuse rule (GAAR) a penalty of 60% of tax due will be charged.

Tax evasion penalties

New civil and criminal penalties are to be introduced following consultation earlier in the year. There will be a new criminal offence for corporate taxpayers who do not prevent their agents from facilitating tax evasion, either onshore or offshore.

There is also a criminal offense for individuals failing to declare offshore income and gains. This will operate regardless of the intention of the individual so there will be no need for the prosecution to prove that the individual was intentionally dishonest.

There are to be civil penalties for individuals in the case of deliberate offshore tax evasion, and some penalties will be linked to the value of the assets on which the tax was evaded. There are also civil penalties for enabling offshore evasion by other parties.

Large businesses tax compliance

Following consultation on large business tax compliance there is to be a requirement for large businesses to publish tax strategies as they relate to UK taxation. There will also be a special regime to combat the problem of businesses engaging in aggressive tax planning. A framework for cooperative compliance by large businesses is to be published. Large businesses have not yet been defined for the purpose of these measures.

Digital tax accounts

The UK government is investing GBP 1.3 million to upgrade digital tax administration and many businesses, landlords and self-employed individuals will be required to update their tax affairs digitally and ensure that their online tax account is updated quarterly. Plans are to be published soon by the government and a consultation will be launched in 2016. The reporting requirements are likely to begin from the year 2020.

Stamp duty land tax

From 1 April 2016 there are to be higher rates of stamp duty land tax on purchases of additional residential property above GBP 40,000, for example on the purchase of buy to let property and second homes. These rates will be 3% higher than the current rates of SDLT. The rates are to apply to both UK and foreign purchasers. They are not however to apply to corporate entities or to funds that make significant investments in UK property. There is to be a consultation on the details of this change.

There is also to be a consultation on reducing the time for filing and payment of stamp duty land tax on property from 30 days to 14 days. The changes are likely to come into effect from 2017/18.

Intangible assets and partnerships

The intangible assets regime is to be clarified in respect of intangible assets that are held by partnerships. This will affect companies holding intangible assets through a partnership. The government has also announced that it is considering a review of the intangible assets regime as part of the more comprehensive Business Tax Roadmap that is to be issued before April 2016.

VAT reduced rate for energy saving materials

This is to be a consultation on legislation to be introduced in the Finance Bill for 2016 to maintain the reduced rate of VAT on energy saving materials in line with EU law. This follows action by the European Commission on the grounds that the reduced rate in the UK is too wide in scope.

Capital gains on residential property

A payment on account of capital gains tax due is to be required within 30 days of completion of the disposal. This will not affect properties where no capital gains tax is due owing to principal private residence relief. This measure is a response to analysis that shows that capital gains tax on residential property is an important part of the “tax gap”, in other words tax that is due but is not collected by the tax administration.

Non-domiciled individuals

There is to be a consultation on changes to the business investment relief rules so the relief can be used to bring more investment into UK business. The business investment relief rules introduced in 2012 permit UK resident and non-domiciled individuals to invest their foreign income and gains in qualifying UK businesses without triggering a taxable remittance. They have not been used enough to date possibly owing to their complexity.

Other

Other important tax measures include:

• Farmers’ averaging of profits is to be extended to five years of profits rather than two;
• Innovative Finance Individual Savings accounts that are to permit individuals to make loans on peer to peer platforms and receive the interest free of tax will be extended to cover debt securities offered through crowdfunding platforms.
• Tax relief is to be restricted for travel and subsistence expenses for workers engaged through an employment intermediary.
• The transitional period for the removal of the exemption from climate change levy for renewable source electricity which began on 1 August 2015 is to end on 31 March 2018.
• A loan made by a close company to a trustee of a charitable trust for charitable purposes is to be exempted from the tax charge that normally applies to loans to participators in a close company.