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In respect of Bill 6 (corporation tax), the tax law rewrite committee has recently published draft clauses

Maclean and another v CRC, SpC 594, 19 February 2007

HMRC have made recent enhancements to their Corporation Tax (CT) Online service.

Limited freedom

A Finnish company which was wholly owned by a company established in the UK made a transfer to the parent company. It was ruled that an intra group financial transfer was not tax deductible under Finnish law when made to a parent company in a different EC state. Such a transfer within Finnish companies both resident in Finland would be allowable.
The claimant appealed saying that this went against article 43 of the EC Treaty which referred to the freedom of establishment.

Sempra Metals Ltd (formerly Metallgesellschaft Ltd) v CIR and others, House of Lords, 18 July 2007

STEPHEN CHARLES provides an overview of the rules for research and development tax relief

DEAN WOOTTEN considers whether high rate start ups should be unincorporated for the first two years.

The House of Lords have found unanimously for Mr Jones in the Arctic Systems case, Jones v Garnett, upholding the Court of Appeal but on different grounds.

Pirelli Cable Holding NV and others v CRC, Chancery Division, 23 March 2007

Interest rates

HMRC have announced new rates of interest for quarterly instalment payments and early payments of corporation tax not due by instalments, in respect of accounting periods ending on or after 1 July 1999. The new rates take effect from 16 July 2007.
The rate of interest charged on underpaid instalment payments of corporation tax changes from 6.50% to 6.75%.
The rate of interest on overpaid instalment payments of corporation tax, and on corporation tax paid early (but not due by instalments) changes from 5.25% to 5.50%.

CT Online service

The Budget 2007 changes may put disincorporation on the agenda for many small businesses, warns PETER RAYNEY

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