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Corporation tax changes to be enacted
20 July 2017 Amanda Darley, Head of Operations and Engagement
Certain corporation tax changes proposed at the Budget, but cut from the previous Finance Bill (now Finance Act 2017) due to the General Election, will be included in the Finance Bill which will be enacted 'as soon as possible after the summer recess'. Some of the measures will still have effect from April 2017. The main corporation tax changes are:
The corporate interest restriction. This legislation will come into effect from 1 April 2017. While there is an exemption for loans from a charity to wholly owned subsidiaries, this exemption does not cover loans from third parties into subsidiaries, and/or any loans between subsidiaries, or upstream loans from subsidiaries to the university. So you will need to consider this if your university group has a net interest expense over the £2 million de minimis threshold.
Changes to the hybrid rules, including the removal of local taxes from the definition of overseas taxes that can be taken into account when determining whether there is a mismatch (from 13 July 2017).
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20 July 2017 
Amanda Darley, Head of Operations and Engagement
