HM Treasury

Taxation, work and welfare

Corporate tax

Corporate tax reform: delivering a more competitive system

The Government has published the document entitled ‘Corporate Tax Reform: Delivering a More Competitive System’ (referred to as the document). This document shows how the Government will work with business to enhance UK tax competitiveness.  It is designed to provide business with certainty over the Government’s plans and support the recovery by giving business the confidence needed to invest in the UK.

The document collects a series of reforms into a single programme.  By doing so, this will allow Government and business to examine the interactions between different elements in a coherent and systematic manner.

The individual chapters of the Corporate Tax Reform: Delivering a More Competitive System document are available below in  Adobe Acrobat Portable Document Format (PDF). If you do not have Adobe Acrobat installed on your computer you can download the software free of charge from the Adobe website. For alternative ways to read PDF documents and further information on website accessibility visit the HM Treasury accessibility page.

Liaison Committee

A Liaison Committee of representatives from businesses has been established to provide strategic oversight of the development of corporate tax policy. A list of members is provided below. The first working group meeting is scheduled for the end of January.

Part 1A: the corporate tax road map

Part 1 considers the reform plan as a whole and sets out how the Government will approach each element.

Part 1 includes:

Part 2: Consultation on the taxation of foreign profits and intellectual property

Part 2 considers medium-term reform in two key areas, the Controlled Foreign Company (CFC) rules and the taxation of intellectual property and R&D tax credits.  Here the Government intends to legislate resulting changes in Finance Bill 2012.

Part 2A sets out proposals to reform the UK’s CFC rules on the key issues of monetary assets and intellectual property.

View further details of the Government’s consultation on reform of the UK’s CFC rules.

Part 2B sets out the role intellectual property plays in the Government’s ambitions for the corporate tax system. It includes proposals to introduce a Patent Box; and a review of the support R&D tax credits provide for innovation, including the proposals of the Dyson Review.

Part 3: CFC interim improvements and reforms to foreign branch taxation

Part 3 provides an update on reforms announced at the Budget for inclusion in Finance Bill 2011 ahead of publication of draft legislation on 9 December 2010.
Part 3A sets out proposals for CFC interim improvements.

View further details of the Government’s consultation on CFC interim improvements

Part 3B sets out proposals for reform of foreign branch taxation.

View further details of the Government’s consultation on the taxation of foreign branches

Further engagement

The Government held open events in HM Treasury on corporate tax reform on:

Slides from these events are available below:

There are no plans for further open events at this stage. Further events will be announced as appropriate.

If you would like to share your views on any area of corporate tax reform, please contact the HM Treasury representative for that area or email

Additionally, the Government has established the Business Forum on Tax and Competitiveness, chaired by the Exchequer Secretary, to consult with large businesses on the UK’s tax competitiveness, including the long term aims of reform of the corporate tax system. 

View further details of the Forum, including meeting minutes

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