Interest - working towards a harmonised regime - draft legislation and commentary for Corporation Tax and Petroleum Revenue Tax

Comments from ACCA to HM Revenue and Customs (HMRC), February 2010.

ACCA is pleased to comment on the above consultation on the draft legislation Corporation Tax and petroleum Revenue Tax within the new common regime for interest. ACCA acknowledges the value of continuing dialogue and feedback in this area.

The draft corporation tax legislation appears to incorporate the existing regime for corporation tax into the new act in the manner expected following the earlier consultations. Although the level of simplification which can be achieved in this complex area of legislation is limited, the new clauses are easier to follow than their predecessors and for this HMRC is thanked. We would point out that businesses likely to be affected by these provisions are in any event going to be the more sophisticated tax payers, and so the need for simplification can be balanced by the desire for consistency and certainty for users of the legislation. By keeping redrafting to a minimum, HMRC reduce the risk of unintended alterations to the effect of the legislation to a minimum.

The clauses for Petroleum Revenue Tax have been drafted on the same basis. Again, the new clauses are easier to follow than their predecessors. ACCA acknowledge the efforts made by HMRC to improve transparency for all tax payers through simplification of the legislation.