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Darling will dig deep to appease taxpayers through a package of tax cuts in this year's Pre Budget Report (PBR)

The current economic climate leaves the Chancellor with limited options but to rely on substantial borrowing to fund a tax cutting policy to bail out struggling taxpayers in the downturn, says leading business and financial advisers Grant Thornton. 

Francesca Lagerberg, Head of Grant Thornton's National Tax Office comments, "To stimulate the economy and support those experiencing difficulty as a result of the downturn, treasury officials are likely to put in place substantial cuts in tax revenue. The significant package is reported to be in the region of £15 billion a year, equivalent to around 1% of UK GDP to benefit the most vulnerable sections of society including pensioners, low income families and the unemployed who are already feeling the harsh effects of the economic downturn."

"One area that the PBR traditionally reviews is the Personal Allowance and NIC bands. However in May, the Treasury responded to the backlash over the abolition of the 10 percent starting rate, which adversely affected low income taxpayers, by increasing the personal allowance from £5,435 to £6,035. But, this move was only to deal with the issue for the current tax year and the Government will now need to explain what it is going to do to ensure that the problem does not resurface in April 2009 for the start of the next tax year."

"The Chancellor, in his annual Mais Lecture, has already made it clear that there are no plans to reduce public spending so tax cuts will have to be funded by borrowing and consequently breaking the golden fiscal rules. The Treasury has experienced a significant fall in tax receipts as expenditure on unemployment benefits increases and stamp duty land tax receipts have declined owing to a stagnant housing market - a large increase in borrowing is likely to be one of few viable options this Government has at its disposal," Lagerberg says.

Will the current savings guarantee be doubled? 

The official guarantee for UK depositors is currently set at £50,000, or £100,000 for joint accountholders. There is speculation that this figure may double to £100,000 after similar proposals were unveiled recently by the European Commission. 

However, Mike Warburton, senior tax partner at Grant Thornton says an increase in the current savings guarantee is unlikely as the Government could not justify the extended expenditure. "The Government is unlikely to put in place measures to encourage saving at a time when tax receipts from property and consumer markets are low and the Government wants to encourage spending to get liquidity back in the market." 

"The collapse of several US financial institutions and the mergers of several others has undoubtedly left savers feeling uncertain about where to deposit their hard earned cash. Anecdotal evidence suggests that savers have flooded Government backed banks that are perceived to be 'safe'. Consequently, nationalised banks have recently had to lower their savers' rates in an attempt to avoid breaching anti-competitive laws. It is currently unclear whether this PBR will see the Government implementing measures to raise the current £50,000 limit or stick strictly to it in the event of another banking collapse."

Inheritance Tax (IHT) - Will a bidding war ensue? 

In the March 2008 Budget the Chancellor restated his commitment to increasing the IHT nil-rate band until 2010. With limited funds, significant changes are unlikely to be made beyond the pre-announced tax free limits of £325,000 for 2009/10 and £350,000 for 2010/11.  

Maurice Fitzpatrick, a senior tax manager at Grant Thornton says, "The condition of the housing market, may leave many who have inherited a property facing a huge tax bill. Traditionally, a property would be sold in order to pay the IHT bill but the average home is taking approximately 24 weeks to sell and many are languishing on the market for much longer and owners are consequently losing value in their property."

"The current law takes the value of the property on the day someone dies and expects the IHT to be paid within six months. With an increasingly difficult property market and falling prices, the executors will find it harder to sell and may find the tax is due before they've got the cash available. It is possible to make a claim to pay tax on a lower value if the property is sold within three years and the value has fallen by £1,000, (or 5% if lower than £1,000) compared to the value at the date of death."

Could a Stamp Duty Land Tax (SDLT) holiday breathe life into an ailing housing market?

Statistics show that 15,600 mortgages were approved for first-time buyers in August 2008, down 45 per cent from the same month last year, according to the Council of Mortgage Lenders (CML). The withdrawal of favourable mortgage products and spiralling mortgage rates has left only those who have access to a significant deposit able to gain approval for a mortgage. 

Karen Campbell, head of Stamp Taxes at Grant Thornton says, "The Government's recent one year suspension of Stamp Duty Land Tax (SDLT) for home buyers purchasing residential property below £175,000 may have provided a glimmer of hope to those at the lower end of the market but it is unlikely to be large enough to boost the market overall especially in the South East region where the average house price is £233,086*."  

Since the suspension, the economic outlook has further declined and this has created even greater pressure on the housing market. "The current state of the UK property market renders the withdrawal of SDLT below £175,000 a relatively small measure given the scale of the property downturn. At present there is a real need for more innovative measures to be put in place to breathe life back into the market. The Government said the stamp duty holiday would last 12 months, but it would not be a major surprise if it were to become permanent."

"SDLT provides much needed revenue for the Treasury at a time when the market is in desperate need of assistance. Could this PBR see the Government take a more radical approach in the short term? It is however, unlikely that this PBR will address a total reform to SDLT but we may see incentives put in place for certain sections of society. After the Bank of England's recent interest rate cut, we may see more stability and hopefully we will see more transactions as a result of banks beginning to lend again," says Campbell.

Income-shifting post Arctic Systems - Any respite for small business owners?

The Government is still publicly committed to bringing in legislation in April 2009 to tackle what it calls 'income shifting'. The measure is mainly aimed at married couples, civil partners, cohabitees, or family members who share business profits that have been generated primarily by the efforts of one individual in the business. This usually takes the form of a sharing of dividends from a company so income passes from a higher to a lower rate taxpayer thus saving tax overall. The prime difficulty for Government so far has been effectively targeting this measure. The controversy surrounding this issue led to the proposal being deferred in April 2008 for one year.

Francesca Lagerberg says, "The main problem is that the Government has not yet been able to devise a method of targeting its proposal on income shifting. To date it has tried to use a mechanism that relied on having to value the contribution of a person to a business. This sort of valuation is almost impossible in a family owned businesses. How can you put a price on who does what to make that business run? How do you value the discussion across the kitchen table on day-to-day business decisions? The concern was that the original proposal would set up huge burdens on small businesses to justify their structure. If this proposal is to come back it needs to be a significant improvement and given the great pressure on small businesses at the moment with an impending recession, the Government would gain some plaudits if it simply decided to let this proposal drop and instead commit to re-energising its longer term review of small business taxation."

Taxpayers' Charter

HM Revenue and Customs (HMRC) has been consulting on introducing a new Charter for taxpayers and further details may be released at the PBR. HMRC's proposals to develop clear guidelines for taxpayers' on their rights and probably their responsibilities is welcome news. Business advisers have argued since the demise of the use of the last Taxpayers' Charter that a revised statement was needed.

Lagerberg says "HMRC's powers have changed significantly in the last two years. It is imperative that taxpayers are kept up-to-date and informed of what is expected of them and what protection they have when things do not go as they should. The Charter is an opportunity to set out a clear statement of a taxpayer's rights and obligations and would bring the UK in line with many other countries. When it comes to taxpayers' rights, the best result would be for the Charter to be encapsulated in legislation to give it real 'teeth' so that it can be fully relied on by a taxpayer. Such a move would potentially form part of a welcome package of tax measures for SMEs."    

Will the taxman take a second bite of the offshore cherry? 

There is increased speculation that HMRC plans to launch a new tax 'amnesty' for an estimated 70,000 investors believed to be using offshore bank accounts to avoid paying the correct amount of tax. An update on this measure is expected in the PBR in an attempt to recoup what the Government considers as lost revenue.

Last year, an estimated £400m was raised when suspected tax evaders were given the opportunity to come clean and pay reduced penalties of 10% during the Offshore Disclosure Facility (ODF).

Gary Ashford, a tax investigations director at Grant Thornton, says, "It is perfectly legitimate for a UK taxpayer to hold a bank account outside of the UK and depending on their residence and domicile status, any interest arising on that account may or may not be subject to UK tax. However some people have used offshore bank accounts to divert money away from HMRC and it is those people that HMRC are targeting. Given the current economic outlook, the Treasury is in need of extra revenue and encouraging people to come clean to pay tax on their offshore accounts is looking like a very real option."

"HMRC is facing growing pressure to show a breakthrough in its investigations. Whether it be information sharing, pressuring private banks to hand over details of account holders or teaming up with other tax authorities, HMRC is determined to gain access to suspicious accounts. It is looking increasingly likely that HMRC will consider introducing another facility for those holding untaxed offshore assets, particularly, in offshore bank accounts to disclose these to HMRC and pay any tax owed."