Treasury forecasts for tax receipts on companies’ foreign profits repatriated
to the UK have puzzled tax experts, following the pre-Budget report earlier this
The Treasury estimates taxes on foreign profits will generate £75m for the
Exchequer in 2008/09, but will cost about £275m by 2012. The reforms to foreign
profits were first proposed in 2007, alongside ‘controlled company’ legislation,
aimed at stopping companies shifting taxable profit outside the UK. A number of
companies, including WPP, the advertising giant, and Shire, Britain’s third
biggest drugmaker, are moving their headquarters overseas.
Deloitte tax partner Bill Dodwell said that he was puzzled by the forecast
for tax receipts and tax loss resulting from the change to the controversial tax
rules, but said the government was right to change them.
‘They think all of a sudden they’ve given away this gigantic amount of money.
It is very implausible. There’s nothing I can see in any of the documents that
support their reasoning,’ he said.
‘It’s a pretty good announcement,’ he added. ‘I’m not sure it’s going to stop
someone emigrating who was keen to do so, but those who were undecided might now
stay and stake a case for what they would like to see,’ he said.
Jonathan Hornby, the senior director of corporate tax at Alvarez and Marsal
Taxand a tax advisory firm was also surprised by the Treasury forecast.
Before the PBR, he estimated the cost to the Exchequer of introducing an
exemption for foreign dividends would be £600m per annum.
‘Most commentators didn’t understand where those calculations came from in
the first place. The Treasury never made the underlying information available,’
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