It comes as no surprise that the Government has continued to focus on anti-avoidance provisions, and the extension of the Disguised Remuneration rules is one example of their approach. Salary sacrifice schemes remain topical as demonstrated by the announcement that the Government is considering limiting the range of benefits that attract income tax and national insurance advantages when provided as part of a salary sacrifice scheme.

What did come as a surprise was the introduction of a lifetime limit (of £100,000) on exempt gains for Employee Shareholder Status shares. Curbing the scope of the tax benefits applicable to these arrangements indicates that they've been used in ways which were not anticipated by the Government when they were first introduced. The impact of this measure is mitigated to some extent by the reduction in the capital gains tax rates. However, the announcement will be disappointing to both companies and individuals looking to use these arrangements, or already using them, and wanting to roll them out further. This is likely to re-focus interest in share plans which will deliver capital gains tax treatment at the new lower rates, such as enterprise management incentives.

There are very significant changes to entrepreneurs' relief (ER), and we mention just two. First, the far-reaching restrictions introduced in 2015 on accessing ER in the context of joint venture and partnership structures will be pegged back. Practitioners and industry objected that the restrictions went too far by interfering with legitimate commercial structures. The government has listened, undoing the offending restrictions with retrospective effect. Secondly, ER will now be available to "external" (non-employee, non-officer) investors who subscribe for ordinary shares in unlisted trading companies where they hold such shares for at least three years. In terms of encouraging investment, that sounds very positive. One consequence though is that the ER rules for share disposals are becoming more fragmented. For example, to be eligible for ER, EMI option holders don't have to hold 5% of the ordinary share capital and neither do external investors, but investors who are employees or officers will still need to have a 5% holding. Query what the rationale is for retaining the 5% holding requirement for such investors, especially given that the employee-officer investor isn't required to have 5% economic ownership.

The most intriguing part of the Budget for me was the brief comment (Red Book 2.44) that there would be rebasing and transitional rules for non-doms becoming deemed domiciled on 6 April 2017. We also had a renewed promise that non-doms would not be taxed on the income and gains retained in trusts settled before the settlor was deemed-domiciled. Together these are clearly good news for a somewhat beleaguered community of non-doms. However, the lack of clarity needs to be addressed quickly. Juxtaposing the announcements about rebasing and trusts suggests that non-doms are in an impossible position where they do not know whether to create a trust before 6 April 2017 (to predate deemed domicile) or after 6 April 2017 (to benefit from rebasing). My suspicion is that rebasing may not be as promising as it appears: I suspect that while the arising basis will only apply to the post-2017 gain, the pre-2017 gain will not escape tax but will remain subject to the remittance basis.

The interaction of the remittance basis with the new lower rates of CGT will also be interesting. The remittance basis treats gains as accruing when they are remitted. This suggests that a pre-6 April 2016 gain remitted after that date may, in the absence of specific rules to the contrary, benefit from the new lower rates. The application of the mixed-fund rules to work out which capital gains are which (and at what rate) may prove a logistical nightmare.

The North Sea oil and gas industry has suffered great hardship as a result of the collapse in oil prices. In the budget the Chancellor announced a reshaping of the tax regime for the offshore oil and gas industry. Two key measures are the reduction of the rate Petroleum Revenue Tax to zero. PRT applies to older fields many of which are being decommissioned. Reducing the rate to zero, rather than abolishing the tax, will allow field participators to claim back historic PRT against decommissioning costs. A second key measure is the reduction of the supplementary charge from 20% to 10%. At the same time the chancellor has confirmed that legislation will be introduced to remove any doubt that historic owners of fields who sell out their interest but retain liability for decommissioning costs will be able to claim full tax relief for those costs. This should invigorate the opportunities for specialists in the operation of late life fields to enter the North Sea Basin.

These measures taken together will be welcome and will support the Government's policy to maximise economic recovery from the North Sea Basin. Whether this will be enough to sustain the industry remains to be seen.

With the Business Tax Roadmap being published, perhaps the Chancellor felt that this was the last opportunity in this Parliament to tinker at will with the tax code. Whatever the reason, businesses large and small had reason to pay attention to this Budget.

The headline grabbing measures affecting property developers and oil companies will monopolise the papers, as will the further changes to loss relief (and a further gouge on the banks). However, a couple of technical issues caught my eye. The consultations on SSE and insurance linked securities are welcome, not least because getting these regimes right could encourage further capital to our shores.

An important related point is how the Government should treat feedback to such consultations seriously. By announcing their intention to implement the BEPS 4 recommendations only weeks after several responses to the public consultation questioned the logic and purpose of these proposals, the Government is giving credence to the cynics who say these consultations are just for show. Given the confirmation that both anti hybrid and interest barrier rules will be effective next year, it will also be interesting to see what impact the EU BEPS package has on domestic implementation.

This was a heavyweight Budget. Perhaps more than many recent Budgets, there was a careful balancing act being performed by the Chancellor.

On the one hand, there were very eye-catching tax rate reductions for corporation tax and capital gains tax, with good news for long term investors, entrepreneurs and small businesses. The reform of the corporation tax loss regime is overdue, and should assist group reorganisations and restructurings. The removal of withholding tax on residual payments made by UK securitisation regime companies also places the regime on a more even footing when compared to Irish, Dutch and Luxembourg securitisation vehicles.

On the other hand, there remains a long shadow cast over the Budget by several changes linked to the progress of the OECD's BEPS Report. These changes are more significant than the annual raft of anti-tax avoidance measures (although there are plenty of those as well). The introduction of the proposed changes to interest deductibility in the wake of BEPS Action 4 for companies above the de minimis interest expense threshold will be a critical moment for UK tax policy, and for UK tax competitiveness. The repeal of the worldwide debt cap and the introduction of the new interest deduction barrier is likely to bring about group reorganisations, debt restructurings and (perhaps above all) additional complexity into the UK tax code. The introduction of interest barrier rules in Germany in 2008 was not straightforward, and there is little to suggest that introduction in the UK will be any simpler (especially if the enactment of the worldwide debt cap in 2010 is anything to judge by).

Introduction of the hybrid mismatch rules, the finalisation of the income-based carried interest rules and new withholding taxes on royalties are also significant changes to the UK tax landscape, all of which will dampen the benefit of headline-grabbing tax rate reductions.

Many OMBs, entrepreneurs and the self-employed will welcome the Budget, with its extension of entrepreneurs' relief to investors, the business rates cut, the reduction in CGT rates and the abolition of Class 2 NICs to name just a few of the tax give-aways.

However, larger businesses are unlikely to view the Budget so favourably. Although the further reduction in corporation tax rates is to be welcomed, the restriction of corporate interest relief, the increase in SDLT rates for commercial property transactions over £1.05m and the restriction on the use of carried-forward losses are likely to increase the tax bill for many large businesses.

With the clamp-down on overseas property developers and the increase in commercial SDLT rates, one can't help think that having squeezed the residential property market for as much tax as possible, the Chancellor now has the commercial property market firmly within his sights.

It's not all bad news though. The insanely complicated worldwide debt cap rules look like they will be repealed and beer and cider duty was frozen.

This was a Budget for David and Goliath. Small businesses benefitted, while big multinationals and their tax transparency came under scrutiny. Once again, the Chancellor overlooked the importance of mid-sized businesses in his plans to get the economy on a more sustainable footing.

When measured against what businesses wanted to see in this year's Budget - fairness, simplicity and certainty - the Chancellor's biggest fail was in simplicity.

Businesses are feeling strangled by red tape and shackled by the complexity of UK tax law. 55% of businesses we spoke to before the Budget wanted to see simplification of payroll taxes, specifically in the alignment of National Insurance and Income Tax. They will be disappointed by the lack of swift action here.

On fairness, the Chancellor introduced measures to target anti-avoidance by large multinationals, which will be welcomed by businesses and the public generally. And in terms of certainty, the corporate tax road map gives stability to the direction of travel with corporate taxes, reducing them to 17% by 2020.

The revenue-raising spotlight has now moved to commercial property and the institutional investment sector. Institutional investors will be affected by the impact on prices and margins of the increase on SDLT to 5% on commercial property transactions above £250,000. A real surprise for institutions investing in residential is the lack of an exemption for institutions to the 3% additional rate on multiple residential property acquisitions. This is a reverse on the original proposals and, whilst the Government would presumably have been concerned about exempting buy-to-let investors generally, it is surprising they could not find a way to relieve the burden for institutional investors who are just starting to come into the sector.

There was a great deal here for private equity. We saw a significant legislative reaction to BEPS with the introduction of anti-hybrid rules and the cap on interest rates from 1st April 2017. PE houses in particular will need to take account of this cap in their modelling when bidding for UK companies. As a result of these measures, we are likely to see less shareholder debt in acquisitions by PE funds.

The quid pro quo for a low corporation tax rate (down to 17% from 2020) is a tougher and more complex corporation tax regime. There are obviously a whole host of significant reforms ahead, including limitations on interest deductions and proposed changes to carry forward loss rules (which are both material money raisers). Property developers are a big loser from this budget (SDLT rates going up for commercial property and a new regime for taxation of overseas property developers). The focus on withholding on royalties is, in retrospect at least, perhaps not that surprising - this is an area of the tax code that hasn't received much attention recently and is replete with complexity and uncertainty (especially around the question of source).

In the round I suspect the Government has deftly balanced the competing objectives of being a vigorous supporter of the OECD's BEPS work whilst preserving the reputation and competitiveness of the UK tax system. Let's hope that's the case.

The big news for incentives lawyers is clearly the introduction of an individual lifetime limit of £100,000 on gains eligible for the CGT exemption through employee shareholder status (ESS). The government has emphasized its continued commitment to ESS but makes it clear that the benefits are "proportionate and fair".

The new limit applies to ESS contracts entered into on or after 17 March 2016, and will not affect arrangements already in place. Whilst the introduction of a limit is perhaps not a surprise given the extremely generous CGT exemption previously available under ESS, the limit of £100,000 would seem to be unduly low (particularly given that individuals give up employment rights in order to become employee shareholders).

The timing of the change may also operate harshly for arrangements which were in the process of being finalised around the time of the Budget - there will be situations where statements of particulars had been issued and independent advice given in the week leading up to the Budget, such that the Chancellor's announcement fell within the applicable seven day cooling off period. It would seem that such arrangements will be subject to the new cap, even though it did not apply when the individuals received their independent advice and it is disappointing that transitional provisions were not announced to deal with this.

It is encouraging that the government has confirmed that the UK will be implementing a group ratio rule as recommended in the OECD report and a de minimis group threshold of £2 million net of UK interest expense. However, it will be important for industry bodies to engage fully with government during the further consultations, for example in relation to third party lending to the private equity, real estate and infrastructure sectors.

The detail of the new tax rules relating to profits from trading directly or indirectly in property in the UK will need to be studied carefully and representations made, if necessary, to ensure that normal investment activity is not adversely affected.

It is disappointing that the government has decided not to introduce an exemption in the legislation relating to second homes for significant investors. This seems contrary to the policy of encouraging "build to rent" projects.

Everyone will recall the furore that surrounded the "pasty tax" a few years ago, however, it appears the proposed sugar tax has had a better reception, and is considered by many commentators to represent a definitive step in the battle against obesity. With two years before its introduction, manufacturers of affected products will need to carefully consider the implications of the proposed two-tier system. In particular, businesses will need to consider factors such as, whether they intend to change their recipes to avoid the tax and/or pass the tax burden onto their consumers.

The reduction in corporation tax from 2020 will be welcomed, but is this necessary? Recent reports suggest that Britain has failed to regain its top slot in a league table of multinationals' favourite tax regimes in Europe, in spite of George Osborne's earlier rate cuts. Will further cuts help? It is not clear whether tax breaks are in any way decisive in businesses' decisions to invest in the UK. Other factors, such as the availability of a local well-trained work force are often cited as being more important than the headline tax rate.

In keeping with a budget that seemed to be focussed on smaller businesses, the Chancellor announced plans to modernise the way companies treat losses to allow greater flexibility. He did not elaborate on the details of how this will benefit UK companies so we will have to wait and see what he has in store - the devil is often in the detail. He did however confirm that the maximum amount of profit that can be offset using past losses will be restricted ensuring that companies making large profits pay more tax.

Once again the Chancellor has unveiled plans to crackdown on tax avoidance. In his latest budget he announced the closure of perceived 'loopholes', including multinationals over-borrowing in the UK to fund activities abroad and then deducting the interest from their UK profits and restrictions on offsetting losses from 2019. From 2018 termination payments over £30,000 will be subject to employer's NICs as well as income tax, which will have a big impact on employers. In addition, the Chancellor remarked on internet VAT avoidance. He plans to take action to stop overseas suppliers undercutting UK businesses (on the internet and in the high street). Businesses and advisors alike will no doubt be keen to see the detailed proposals as and when they are unveiled.

The cut in capital gains tax from 28% to 20% in three weeks' time is a significant change which will be welcomed by investors. The government will be hoping that cutting the rate will raise tax as people take the opportunity to crystallise gains. It is notable that the old rates remain in place for gains on residential property and carried interest, areas that have previously been the subject of increases.

One of the main targets for anti-avoidance measures were overseas developers of UK property. Wide ranging anti-avoidance provisions will, unusually, take effect when the legislation is introduced at Report Stage. Non-UK resident corporates will be charged to corporation tax on trading profit realised from developing UK land irrespective of whether they are conducting the development through a UK permanent establishment. The principal aim of the legislation is to tax non-UK tax resident developers on the same basis as UK resident developers computing development profit on the basis of UK corporation tax computation principles rather than in accordance with the attribution of profit to a UK permanent establishment (if in fact the non-UK entity is developing a UK property at all through a UK permanent establishment under existing rules). Moreover, amendments have also been made with effect from Budget Day to the Guernsey, Jersey and Isle of Man double tax treaties specifically giving the UK taxing rights over gains realised in relation to UK land (including gains realised on disposals of shares in land rich companies).

As expected, this was another reasonably "quiet" budget for changes specifically targeting employee share plans - with the notable exception of the new lifetime limit of £100,000 on the CGT exempt gains for disposals of employee shareholder shares (ESS) acquired after Budget Day. Whilst the exact form and timing of the restriction of the availability of relief for ESS arrangements was a surprise to many, it follows from more general speculation that ESS might be the subject of legislative change.

The reduction in CGT rates will be welcome news for those holding shares within the capital tax regime and not otherwise subject to entrepreneurs' relief. With dividend tax rates also changing from 6 April, companies will want to review their communications with share plan participants to ensure that UK tax information is fully up to date.

Although no additional significant pensions changes were announced, the wider financial package for employees, looking at pensions, benefits, share plans and other savings arrangements such as use of ISAs, will remain an area of interest, and changing rates and thresholds will all be relevant in considering the overall picture.

I liked this Budget, and so will a lot of my clients. After the "Autumn Update on Work In Progress" last November this was a meaty package of tax measures with two consistent themes: supporting smaller businesses over large multinationals (levelling the playing field a bit?) and continuing to use the tax system to redirect wealth creation away from property investment and back into private companies that actually make and do stuff. On the latter, effectively extending Entrepreneurs' Relief to longer term business angel investors in unlisted trading companies is particularly eye-catching, and will provide a very welcome incentive where EIS is not available (and, we hope, will lead to fewer sleepless nights for advisers given the myriad complexities of EIS). The backdated amendments to existing Entrepreneurs' Relief are very welcome too, and proof that HMRC does listen and that proactive consultation works (well done CIOT and all those others who contributed to the extended dialogue with HMRC on this), although it is also worth reiterating that proper consultation before rushing in such ill thought out legislation would have been even better. And we see an immediate increase in SDLT for higher value commercial property. The difference in SDLT rates between high value residential and non-residential property is still eye watering though, and one hopes that this is not the beginning of a levelling of that particular playing field.

There were a number of new tax breaks announced today and incentives for small businesses. However, against a background of lower than expected growth figures and a desire to eliminate the deficit by 2019/20, these have been accompanied by a number of tax raising initiatives (mostly falling on larger businesses) and a move to close certain perceived loopholes. There is quite a lot to get through, but the items that have caught my eye are: the proposed changes to offshore property developers, accompanied by anti-avoidance rules which take effect now; and the proposed changes to the loss relief rules. It is also interesting how the deferral of the change to corporation tax payment dates is timed to give a handy uptick in corporation tax revenues for the very period in which the Chancellor has aimed to achieve a budget surplus.

In the Business Tax Roadmap, the Chancellor highlights the various measures to tackle aggressive tax planning and ensure a level playing field with large multi-nationals paying their fair share of tax - it is hoped that the Government will also ensure a level playing field when considering measures to facilitate effective dispute resolution, in particular as a result of actions taken following the BEPS project, and which should necessarily involve effective and adequate procedures to protect taxpayers' rights, minimise unintended taxation and reduce uncertainty.

The headline was the introduction of a lifetime allowance of £100,000 of exempt gains arising from employee shareholder shares ("ESS"). This will severely restrict the future attractiveness of ESS. Those who already hold such shares will be relieved that they continue to benefit from the full exemption from capital gains tax ("CGT") on disposal. It is not yet clear whether, if your ESS documents allow for more than one issue of ESS, any issue of ESS after 16 March 2016 pursuant to an existing agreement will be subject to the lifetime cap. This is because the guidance refers to the acquisition of shares in consideration of an employee shareholder agreement entered into after 16 March 2016 rather than the issue of shares after that date.

The other significant announcement related to the introduction of a tax charge on outstanding, untaxed loans from so-called "disguised remuneration schemes". The charge will apply to any such loans in existence on 6 April 2019. This will force companies with unresolved disguised remuneration planning issues to reconsider their approach to settlement with HMRC. In effect, HMRC has acted to prevent the outcome of the Glasgow Rangers appeal from thwarting their attempts to recover the tax that they consider to be due. Rather than enforce the current law as they think it should apply, HMRC have changed the rules to allow them to collect what they consider they are owed.

As per usual, a panoply of measures with the aim of reducing tax avoidance and tax evasion will be introduced. No sweeteners have been added.

The new measures to deal with "serial" tax avoiders will include a special reporting requirement and penalty for those whose latest return is inaccurate due to the use of an unsuccessful structure. Controversially, those who are determined to have abused reliefs persistently also may face restrictions on their access to certain tax reliefs.

A new criminal offence of failing to declare offshore income and gains (which will not require an intention not to declare the income or gains to be proved) will be introduced. The criminal offence of failure (by a corporate) to prevent facilitation of tax evasion is likely to be introduced before 2017.

HMRC often take the view (notwithstanding the jurisprudence to the contrary) that a taxpayer cannot rely on a legal opinion as to the efficacy of a tax avoidance structure to avoid imposition of a penalty for an inaccurate return. The Government intends to consider the case for introducing a statutory definition of "reasonable care" in avoidance penalty cases, so as to prescribe that reliance on generic legal advice that has been received via the promoter of the structure will not suffice.

There were more significant tax changes ‎announced than I had been expecting, including one - SDLT on non-residential property - which no doubt generated the burning of some pre-midnight oil. For me, the main surprises were in the CGT regime.

With the government already concerned about ‎tax planning to benefit from the large differential between the CGT and income tax rates, why has George Osborne increased that differential further? I worry that a consequence of this will be heightened anti-avoidance measures ‎in the response later this month to the consultation on the taxation of company distributions - beyond the TAAR and changes to the transactions in securities rules, which are very broad where a close company is involved.

The extension of entrepreneurs' relief to long-term investments in unlisted trading companies makes the relief a misnomer: it is not entrepreneurial to make a passive long-term investment in shares. This seems to act as a fall-back for those investments which do not benefit from EIS or SEIS relief.

I am surprised that the perceived abuse of ESS has been addressed by the introduction of a cap on the amount of eligible gains, ‎rather than seeking to target the audience at which the relief was aimed. I see the cap as only a first step in arriving at that position.

I am not complaining about any of those measures. However, I am struggling to discern any coherent logic in the Chancellor's approach to them.

The third major set of tax announcements in less than 9 months saw the Chancellor determined to help business and entrepreneurs, though his room for manoeuvre was distinctly limited. The prospect of a further reduction to corporation tax (albeit in 4 years' time) was eye-catching, and the revision of the loss relief system will be greatly appreciated by many businesses. Introducing restrictions on deductibility of interest was expected following the BEPS reports but, at 30% of UK earnings, the Government has taken the path of least resistance on this. Potentially of most significance was the extension of entrepreneurs' relief for investors in unlisted companies and the reduction in CGT rates on investments in shares.

But for every winner there has to be a loser and the real estate sector was a big loser. The higher rate of CGT for investing in residential property seems to lack any logical justification (even if politics would demand it) and withdrawing the prospect of an exemption from the additional 3% rate of SDLT for portfolio purchases of buy-to-let residential properties (with two weeks to go before the rules change) has caused great confusion and disappointment. Worse still was the unpleasant surprise of an additional 1% SDLT on all large commercial real estate transactions (introduced overnight). It was depressing to see, yet again, major tax changes for an important sector being announced with so little notice. For a Government that professes to be on the side of businesses, there has to be a more business-minded way of doing things.

Having recovered from the cruel blow that I am not a young person so far as the lifetime ISA is concerned, I was pleasantly surprised (for my clients) with the confirmation that individuals becoming deemed domiciled next year will benefit from a tax free uplift of all their foreign assets to market value as of 6 April 2017. Many details still require clarification, including the trust distribution tax suggested in November's consultation paper and the operation of the inheritance tax extension to UK residential property held indirectly via offshore companies. The consultation on the latter was initially due at the "end of the Summer [2015]".

There was good news for investors with the reduction in the headline capital gains tax rate to 20% and the (rather generous) extension of entrepreneurs' relief to those merely investing in unlisted trading companies. Finally, it would be nice if somebody in authority could finally decide on an appropriate rate for CGT as the last 18 years have seen 40% with indexation, 40% with taper, 18%, 28% and now 20%.

Perhaps the headline for this Budget could be "Small business, good; big business bad". The measures to help SMEs - the doubling of the rates of relief and increased thresholds for small business rates, reduction in the corporation tax rate to 17% from 2020, and the extension of entrepreneurs' relief - have brought the Chancellor some plaudits. Larger businesses will be more sanguine. Although some of the pain was predictable - the confirmation of the introduction of a 30% interest barrier and new hybrid rules fall in this category - some was not. One such measure was the restriction on the use of carried forward losses, which will restrict the availability of carried forward losses of companies with profits (before the use of losses) in excess of £5 million to 50% of those profits (25% for banks) from 1 April 2017 (subject to a slight sweetener in increased flexibility to use carried forward losses against wider categories of income and against profits of group companies). This will increase the risk of companies and groups paying tax on notional profits. At least the publication of the business tax roadmap will allow companies to see some of the pain coming. That will however not be the case for the new withholding tax on royalties and the treaty override for withholding tax royalty payments which take effect immediately. So much for tax certainty.

So far as the revenue-raising tax measures are concerned, there is no really standout one. Various BEPS-related measures are being implemented, in particular changes to transfer pricing methodologies and withholding taxes on royalties, which will need to be considered carefully. A long-surviving tax avoidance structure for property development has its time called. For the asset management industry, the income-based carried interest rules are being finalised, which are intended to restrict the capital gains tax treatment of carried interest receipts to, broadly, the private equity industry. Clarification of technical aspects of partnership taxation should be helpful, but the cynic in me notes how that sort of initiative tends to result in elucidation more advantageous to HMRC than to taxpayers. Otherwise, while the various new reliefs, allowances and reductions in rates will be welcome, it is the proliferation of these that makes compliance difficult for the ordinary taxpayer and can produce anomalies that open the way to tax avoidance schemes.

There are big changes in this budget for business. The headline grabbing item may be lowering the rate of corporation tax (again!) but the changes to interest deductibility, restriction (or is it a relaxation?) on use of carry forward losses, hybrid mismatch rules, measures to change taxation of property development and changes to withholding tax on royalty payments will be of much greater significance for many corporate tax payers.

Even given the absence of changes to tax relief on contributions trailed earlier this month, this Budget was not altogether lacking in pensions content.

The principal change was the proposed introduction, from April 2017, of a new Lifetime ISA for individuals under age 40 with an annual allowance of £4,000 in contributions, and a 25% uplift in bonus from the Government for savings made up to age 50. Funds, including the bonus, can be used for a first home purchase from 12 months after opening the account, and can be withdrawn (with bonus) from age 60 for use in retirement. Withdrawals can be made at any time for other purposes, but the bonus element plus a charge would then be forfeited. Is this a precursor to the gradual introduction of ISA-style pensions for everyone?

The 25% tax free lump sum is retained, and the reductions in the Lifetime and Annual Allowances announced in 2015, and applying from April 2016, are as expected. The Government's concern about the growth of salary sacrifice continues and a limit on the range of benefits to which it applies (other than pension saving, childcare and health-related benefits) will be considered.

The extensions to entrepreneur's relief are welcome, for example holdings in joint venture companies may qualify as trading companies (this change backdated to 18 March 2015). However the headline grabber is the extension of entrepreneur's relief to investors in newly issued shares in unlisted trading companies (subject to a 3 year holding period). This, and the reduction in the headline top rate of capital gains tax from 28% to 20%, show that the Government is still keen to encourage share ownership, particularly in private companies. The imposition of a lifetime limit of £100k on employee shareholder share (ESS) gains for ESS shares issued after today is perhaps unsurprising - it was (and remains for ESS shares already issued) a very generous relief when an unlimited amount of gains (on the first £50,000 worth of shares as valued at issue) were exempt. Further proof that the Government doesn't like carried interest - if any further proof was needed - is given by the fact that the cut in the headline top rate of CGT from 28% to 20% doesn't apply to carried interest. One open question is whether the new investors' entrepreneur's relief will apply to carry - time (and draft legislation) will tell.

A generally "safe" Budget, with the looming EU Referendum very much at the forefront of the Chancellor's mind, this Budget was nonetheless not without surprises. Apart from the headline grabbing new "sugar tax", in the form of a soft drinks industry levy, the Chancellor made substantial changes to both stamp duty land tax ("SDLT") and capital gains tax ("CGT"). From 6 April 2016, the higher rate of CGT is reduced from 28% to 20%, while the basic rate is cut from 18% to 10%. However, an additional 8% will apply to transactions in either residential property or carried interest. SDLT on commercial transactions moves to progressive rates, as is already the case with residential properties. Rates on purchases of up to 5% (and a higher 2% band applying to rent under leases where the NPV of the rent exceeds £5m) means that the new regime will generally be more expensive. Turning to the additional 3% SDLT on the acquisition of residential properties, it is surprising that there will be no exemption for corporate investors, even if they are widely held funds. Lastly, the government presses ahead with BEPS implementation, by committing to a cap on interest deductibility either by reference to net earnings of the worldwide group or 30% of UK taxable earnings.

This is a step change for large groups because the UK has always enjoyed a very generous interest deductibility regime. As a result, businesses have been eagerly awaiting an announcement on the ratio to be used in the fixed ratio rule and the method to be used for a group ratio. The proposal to use the maximum fixed ratio of 30% recommended under the OECD proposals is welcome. For a number of groups, this could still substantially limit interest deductibility so the application of the group interest rule will be important. Unfortunately, there is no suggestion that third party interest expense will escape the restrictions as this would be contrary to the OECD recommendations with which the Government wishes to comply.

Targeting permanent establishments goes beyond the OECD recommendations and will significantly extend the scope of the proposed anti-hybrid rules. As well as impacting financing structures this could have an adverse impact on groups who operate their trading activity through branch structures if payments are being made between branches and/or the head office. It will be necessary to assess the detailed impact of these proposals once revised draft legislation has been published.

The immediate reaction as a tax professional was "there's quite a lot of stuff this year isn't there?" The relaxation to the rules relating to carried forward losses is to be welcomed but the restriction of the availability of loss carry forward for large companies, combined with the restrictions on interest deductibility, will have a wide impact. It may particularly affect special purpose companies with tightly controlled cashflows, such as project finance companies, which would do well to examine the potential impact on financing covenants and coverage ratios.

The measures to counter treaty shopping are a direct outcome of the OECD's recent BEPS work. The widening of the scope of the withholding tax rules to include additional classes of income from intangible assets such as trademark royalties and payments for the use of trade names is an interesting development. The UK has long been an outlier when it comes to the taxation of royalties and these changes will bring the UK's approach more in line with the internationally accepted definition of a royalty payment. Companies which are currently paying royalties without deducting the full rate of income tax either because of the application of a double tax agreement or because the payments are not currently subject to withholding under domestic law should review the draft legislation carefully once it becomes available to determine whether their obligations have changed.

From 1 April 2017 only 50% of taxable profits can be offset by carried-forward losses. The restriction is intended to apply to profits in excess of £5m. Most of the G7 countries operate similar restrictions on loss utilisation. The £5m allowance will mean that the majority of corporate tax payers should not be affected by the restriction but clearly large companies that have unutilised tax losses will now have their relief deferred over a significantly longer period.

The extension of withholding tax to brand royalty payments from this summer, together with the introduction with immediate effect of a main purpose anti-avoidance rule for withholding tax on annual payments and royalties, to prevent treaty shopping, will require some multinationals to review their existing arrangements. Many more will need to assess the impact of the BEPS-driven restriction on relief for interest expenses, to 30% of EBITDA, from next April.

The change in the use of carried forward losses is a tax-raising measure, at least in the shorter term: the use of all carried forward losses will be limited to 50% of profits, while only losses incurred after April 2017 will benefit from greater flexibility. The further restriction on the carried forward losses of banks will leave those which were not bailed out feeling hard done by.

A potential trap for the unwary is a new measure, introduced with immediate effect, requiring the cash equivalent value of non-monetary receipts to be brought into account in computing trading profits. Although apparently aimed at avoidance, it is an override of the requirement to compute trading profits in accordance with GAAP that is of general application and may produce some arbitrary results.

Budget 2016 has been a masterpiece of misdirection by the Chancellor. For the business community, he has delivered a number of headline grapping rate cuts and tax incentives while, on a rough cut of the Treasury's numbers, more than covering the tax cost of these changes with new tax-raising measures that are generally less transparent and difficult to understand.

For example, the corporation tax reduction looks good but will cost the government nothing until 2020. The CGT rate cuts will also look like a positive change, but excluding residential property is a significant carve-out since this is one of the most common assets on which taxpayers might make a gain. Against these ostensibly beneficial changes, a whole range of changes are to be introduced that are projected to raise many billions of additional tax revenue. These include the interest deductibility cap, the 50% restriction on carried forward losses and the SDLT increases.

There are positives though. The interest cap has been set at the high 30% level and the de minimis interest expense threshold increased to £2m, lessening the impact of these important changes. The loss restriction comes with the carrot of greater flexibility on the use of carried forward losses and some new incentives such as the so called "Investors' Relief" are interesting.

One specific observation on the new "Investors' Relief" is whether perversely this might actually encourage greater use of personal service companies, something the Government is actively seeking to discourage through other changes? The relief is only available for taxpayers who are not employees or directors but, unlike Entrepreneurs' Relief, seems to have no minimum shareholding requirement. Could employee/directors who do not qualify for Entrepreneurs' Relief be incentivised to operate through a PSC to access Investors' Relief?

In summary, there have been more unexpected changes in this Budget than for a number of years, recreating the Budget Day atmosphere of old! However, ultimately for business this continued change and upheaval in the UK tax system is very unhelpful. It is hoped that since many of the measures announced in the Budget appear in the Business Tax Road Map document that is intended to map out Government tax policy over the rest of this Parliament, there will be fewer changes and surprises in the budgets to come.

The business community will be relieved to hear that the Chancellor hasn't made any radical changes to entrepreneur's relief. The extension to the entrepreneur's relief rules to long term investors will be viewed positively but there will be disappointment in some quarters that the change does not cover employees or directors. The overall reduction in CGT rates means that the exact scope of the changes to the Transactions in Securities rules which were announced in the Autumn Statement will become even more significant and will be pored over with interest when the Finance Bill is published next week.

The technical changes to the entrepreneur's relief rules relating to the treatment of JV companies and partnerships are good news for investors and will be welcomed by them.

Many of the measures announced at Budget 2016 that will affect multinationals were not unexpected, not least the introduction of an interest barrier (set at 30% of UK earnings, subject to certain release valves) and re-confirmation of the implementation of the anti-hybrid rules, both resulting from the BEPS project. Additional protections against base erosion from royalty payments were less well trailed: most notably, withholding obligations will be extended to forms of royalty payments not previously in scope. The further reduction of the main corporation tax rate to 17% from April 2020 and group-wide availability of losses carried forward after April 2017 will of course be welcome, but cutting in half the ability to set off carried forward losses against profits above £5 million and further restricting the utilisation of losses carried forward by banks leave a rather sour aftertaste. Details of most of these measures are currently sparse and, in some cases, subject to consultation in due course. The Chancellor's continued tinkering around the edges of an already complex system may well lead multinationals to reconsider whether Britain is indeed as open for business as the Government might like to present it.

Notwithstanding the dangerous cocktail of risks of which the Chancellor initially warned, he found plenty in his martini glass to shake things up for capital investors.

A drop in the headline rate of capital gains tax to 20% and a new "investors' entrepreneurs' relief" will be welcome, if surprising to those who feared that having tied his hands on the ability to raise income tax, NICs or VAT, Mr Osbourne might set his sights on increases in CGT.

However, this is tempered somewhat in the detail. The inability of carried interest holders or real property investors to access the lower rates where they are making genuine capital gains may appear arbitrary to some, while lack of a 5% holding threshold for "investors' entrepreneurs' relief" means that there will be a material difference in tax rates between employee investors and external investors with small holdings.

Employee shareholder status could plug this gap, but the biggest news for employee shareholders will be the capping of the relief at £100,000 of lifetime gains for shares issued after 16th March. This is a move by which few will be surprised but which may disappoint teams who find themselves caught up in the 7 day cooling off period and therefore unable to issue their shares in time.

There was a lot in this budget for incentives lawyers. The big surprise was capping shares for rights gains to a lifetime limit of £100,000. SFR remains the only tax advantaged arrangement for many companies so I expect these plans will continue not least because £100k of tax free gains is better than nothing and because it remains possible to agree share valuations with HMRC in advance if acquired through SFR thereby de-risking acquisitions for employees. The extension of entrepreneurs' relief to long term external investors may make it possible for consultants to access the 10% rate (depending on the detail) and creates an anomaly as the 5% minimum ordinary shareholding requirements will not apply to investors (potentially including consultants) but will continue to apply to employees and office-holders.

The government has finally published draft legislation for the 3% additional SDLT rate for second residential properties. Anxiety levels among clients have been rising since November 2015 when the measure was first announced (a generally unforeseen development). However, it has been impossible to advise with any certainty because there has been no draft legislation until now. Clients have found this extraordinary and I have had to agree that the hurried approach to its introduction has been unsatisfactory.

The property industry has predictably been lobbying hard, but has only been successful in toning down the proposals in very limited ways. Specifically, the 18-month period allowed for replacement of a main residence has been extended to three years. In addition, there will be an exemption for individuals who have inherited a small share in a dwelling in the last three years and a marginal loosening of the treatment of separating couples.

However, there is no exemption for significant property investors, which is a major blow for the industry. Further, where a second property is acquired prior to the sale of an existing property, the taxpayer is required to pay the increased rates up front and reclaim the excess later - a villainous cash flow cost in the context of most home purchases.

Clearly the intention of the measure was to curb the rise of the holiday home and the buy-to-let, the proliferation of both of which is perceived to have caused damage to the local communities of certain areas. However, the measures go much farther than this, and have some rather surprising consequences. In particular, the government has confirmed that it is intended that the surcharge will apply to purchases by non-UK residents of a first home in the UK where that non-resident owns other homes worldwide. This is a pretty bold move in terms of the territoriality of a domestic tax measure. And as to how the government intends to police this provision is unclear. It is certainly going to result in some awkward questions asked of clients by conveyancers and extended internal risk management procedures.

The measure may also deter parents co-purchasing property with their children. An odd result for a Conservative Party measure, and one which has inflamed the suggestion that the ill-thought out consequences of some of the recent measures demonstrates a lack of coherent policy in this area.

The standout change in policy for the new 3% additional SDLT rate is the removal of the proposed relief for the purchase of "15 or more" dwellings. This is clearly bad news for those buying portfolios of residential stock. Whilst multiple dwellings relief (MDR) will still remain to ensure SDLT will only arise on the average unit price, the rate of SDLT on each "slice" will now be caught by the 3% increase. This is clearly bad news for investors into PRS and an odd policy move given the general desire to promote investment into this sector. The Government seems to have decided that being seen to favour larger institutional landlords buying multiple properties over smaller scale landlords cannot be justified. The only real relief from the additional rate is therefore where an individual is replacing their main home. Finally, it should be noted that the purchase of 6 or more dwellings as part of a single transaction can still be treated as non-residential if this gives a better result than MDR - but the top rate of SDLT for non-residential and mixed use property is increasing from 4% to 5% on the slice of the price over £250,000. All in all, unwelcome news for the sector.

So when was the last time we had a proper extension to the UK withholding regime? The business tax roadmap came with a welter of major works that businesses will need to navigate and soon. They will need to think hard about their IP arrangements given the imminent extension of royalty WHT, and their loss planning, in addition to the interest deductibility cap and hybrid provisions that we were expecting. You could be forgiven for thinking that the Chancellor has more than one eye on the state of the books for the next election: the further cut in corporation tax rates will not be felt in this Parliament, but accelerated CT instalments dates still will. The confirmation of the higher 30% ratio and group rule for the interest deductibility cap are welcome. That said, it's clear BEPS is an opportunity to shore up the local tax base while acting as a good global citizen, and it will be interesting to see how far other countries go down that path.

It is an odd Budget - handing out candy with one hand, while taking it back elsewhere. The surprise reduction in capital gains rates is clearly a positive step and should help spur investment. However, the top income tax rates remain too high, and while HMRC have shut down most of the accepted tax planning routes, the new 27 percent differential between the highest income tax and capital gains tax rates means that the search for new ways of achieving capital gains treatment will increase.

One might have hoped that the third Budget in twelve months would be relatively low-key. Not a bit of it. Forced into a late U-turn on plans for further reform of pensions, the Chancellor has instead given many individual taxpayers the prospect of some jam today - with capital gains tax rates tumbling from 6 April - and more jam tomorrow - with the 40% income tax threshold increased to £45,000, the annual ISA limit increased to £20,000, and a new savings products for the under 40s in the form of the "Lifetime ISA", all from April 2017. The £1-for-£4 bonus on the Lifetime ISA looks attractive, but the money is essentially locked away until the saver buys a house or reaches 60. With the new soft drinks levy in mind - a novel form of "sin" tax from 2018, to sit alongside duty on tobacco and alcohol - the jam had better be sugar-free.

Instead of further restrictions to entrepreneurs' relief, we have instead corrections to restrictions introduced in 2015, and a new form of ER for long term investors holding an interest for at least 3 years, without the need to be an employee. The tax-free bonanza for employees giving up rights in return for employee shareholder shares is over from 17 March, with the capital gains exemption capped at £100,000 for new shares. Those lucky enough to hold ESS shares issued before the Budget will not be too concerned.

Having reformed the slab system of SDLT for residential property in December 2014, it was only a matter of time before similar changes came to non-residential and mixed real estate, with the top rate increased to 5%. The transfer tax will be slightly less for purchasers of commercial property paying up to £1.05m, but could be considerably greater for those paying more. Lessees will see SDLT bills increase by 1% to the extent that the net present value of rentals exceeds £5m.

In contrast to previous years, the 2016 Budget contained much that was of interest in the business tax context. As expected, there were updates around the implementation of the OECD BEPS project, non-dom taxation and income-based carried interest, as well as the usual soundings around tax avoidance. Consistent with previous policy the headline rate of corporation tax was cut further and the "slab" system of SDLT abolished with respect to commercial property transactions. Most strikingly, it appears that the landscape relating to the oil and gas tax regime, deductibility of interest and loss relief will undergo a significant change, and the gap between income and capital gains tax rates will be widened. Given that this gap has frequently been cited as a driver for tax anti-avoidance, it is not clear whether reducing CGT rates further is a sensible decision.

While the Chancellor's announcements on business rates appear good news for small businesses, they do pose questions for the ability of local government to continue to deliver services which businesses and their employees rely on. For councils comparing the Autumn Statement with today's Budget, it could be a case of the Lord giveth and the Lord taketh away.

The Government has made great play of the £26 billion annual business rate pot being devolved to local councils from 2020. Today's news of an increase in business rate thresholds and indexing to the lower Consumer Price Index, rather than higher Retail Price Index, suggests that the pot could, in reality, be smaller than many councils had expected by that date. In effect, councils might be getting 100% of a smaller pot rather than 50% of a larger pot.

This has been an action packed Budget with measures impacting businesses and individuals alike. The Chancellor has performed the conjurer's trick of raising tax revenues through a raft of revenue raising and anti-avoidance measures whilst at the same time reducing the main rate of corporation tax to a new low of 17% by 2020. This continues the now well-articulated theme of presenting the UK as one of the most competitive corporate tax regimes of the G20 whilst at the same time sending out the message that whilst businesses can expect business taxes to be low, they still have to pay their fair share of tax (whatever that means). Another party trick which no-one had anticipated was the reduction in the rates of capital gains tax from 28% to 20% for higher rate taxpayers (18% to 10% for basic rate taxpayers).

I particularly welcome the amendments to entrepreneurs' relief, as I was involved in the discussions with HMRC. In last year's Budget a number of changes were made to the relief "to prevent avoidance", but the changes went far beyond the intended targets and caught a wide range of commercial scenarios, such as preventing business owners from passing businesses on to their families. HMRC has listened to the concerns of the tax profession and has amended the changes to hit only the intended targets. The amended rules will also be back-dated to the dates of the original changes. This is a major success for a collaborative approach between the tax profession and its HMRC counterparts and involved a huge amount of work by a lot of tax experts effectively working voluntarily.

Other positive measures for small companies include further reductions in corporation tax to 17% from 2020, more flexible use of losses, probably from 2017, and reductions in business rates, as well as a new entrepreneurs' relief for investors in unlisted companies. Less happily, there is an increase in the tax charge on loans to shareholders and a raft of new anti-avoidance measures that are likely to make life more complex for the average business owner.

Apart from the sugar levy, and of course the freeze on whisky duty, two measures stand out for me, each of which are likely to be welcomed by businesses trading within the UK.

First, the limit on multi-nationals setting interest off against taxable profits (set at 30% of EBITDA, and payable to independent third parties). For as long as I can remember, multi-nationals have routinely organised their affairs so that intra-group interest is paid by debtor companies in the UK to creditor "finance" subsidiaries in eg Luxembourg or Liechtenstein in circumstances that are outside the scope of current anti-avoidance legislation such as transfer-pricing and "unallowable purposes". This enables the multi-nationals to say that they "pay all the corporation tax that is due in the UK". This measure foreshadows one of the OECD's BEPS action plans, and is another step in the gallant quest to make UK subsidiaries pay UK tax on the true economic results of their trading activity.

Second, the provision designed to curb VAT fraud committed by offshore companies who store goods in the UK but sell them online through the websites of Amazon and e-Bay without accounting for VAT. This is being done by making Amazon and e-Bay liable for the lost VAT if traders using their websites have failed to register. This neatly transfers the burden of policing their websites to Amazon and e-Bay themselves, and is likely to be warmly welcomed on the hard-pressed British High Street.

The existing array of measures to promote employee share ownership and employee ownership remain intact, and so this amazing era for the growth of ESO and EO continues. But there is a Back to the Future theme in Budget 2016 with the reintroduction, in effect, of taper relief for some employees and the Chancellor reminding us why we have employee shareholder status.

The reduction in capital gains tax rates to 10% and 20% (except for residential property and carried interest) will encourage share ownership generally. Many at successful employee-owned companies, such as Gripple Limited, were upset by the loss of the 10% CGT effective rate when taper relief was withdrawn in 2008. An employee with gains (exceeding the annual exemption) will from 6 April 2016 again pay tax at 10% if the gains fall within the unused part of his or her basic rate band.

Nick Clegg, as Deputy Prime Minister, was in the news for championing employee ownership in 2012. ESS meant George Osborne also hit the headlines. His "shares for rights" idea was presented as a "radical change in employment law" and his 2012 Conference Speech did say it was designed for start-ups. Only 16 out of 139 responses to the consultation document agreed. Many assumed ESS was really meant as a way to allow private equity to incentivise key individuals who were unconcerned about the loss of some employment rights. Exempt gains from employee shareholder shares issued from 17 March 2016 will now be capped by a lifetime limit of £100,000. The Chancellor is once more reminding us that this relief provides "vital flexibility for early stage firms".

Focusing on cross-border supply chains, the Treasury has moved decisively to tighten up the UK's royalty withholding tax rules, with a variety of significant measures. The first is a domestic law treaty override which may operate to unilaterally deny treaty benefits for royalties paid to connected persons from 17 March in respect of UK patents and UK source copyright and design rights, and annual payments. This will apply where it is reasonable to conclude that the payment is made in respect of arrangements which have a main purpose of obtaining treaty benefits where this is contrary to the object and purpose of the treaty. Although broadly consistent with the OECD/G20's recommendations on targeting treaty abuse through BEPS Action 6, this measure calls into question the value and purpose of seeking to agree an acceptable multilateral solution to implement the OECD's proposals with the UK's treaty partners. The scope of the measure in practice remains to be seen - taken at its narrowest, it can be seen as a super-charged Indofoods test, targeting conduit arrangements where the ultimate IP owner is resident in a non-treaty protected jurisdiction, but it could also potentially target triangulation and other arrangements which are increasingly seen as treaty abuse where the arrangement is divorced from substance or another commercial purpose. Second, the Treasury has announced proposals to widen the scope of the domestic UK withholding tax charge to include royalties paid in respect of a broader range of IP, including trademarks and brands. Third, the rules on the source of royalties will be overhauled to impose a withholding charge where royalties are connected with the UK permanent establishment and finally, the scope of the DPT will be widened to include withholding tax paid in respect of a deemed UK permanent establishment. Taken together, this package of measures will cause considerable concern for those multinationals who continue to have IP in non-treaty protected territories, or in treaty protected territories where the IP is divorced from substance and not otherwise subject to tax.

The big changes for our clients are clearly around the changes to the CGT rates and the employee shareholder status exemption. Perhaps we could call the new entrepreneurs relief rules for long term external investors "business asset taper relief"? The continued lowering of the corporation tax rate appears at first to be good news for many companies. However with the changes to loss relief rules this will not equate to a reduction in tax for many corporates. Additionally, we are on the cusp of the UK becoming a corporation tax haven and this is likely to give rise to additional complications for some multinational groups. I think the changes to the withholding tax treatment of royalties are on the whole sensible. I do hope however that they take the opportunity to simplify the legislation.

The Government announcement that it will carry out a review of the substantial shareholdings exemption (SSE) came as something of a surprise. However, the review to look at whether the SSE still meets its original policy objective and whether there could be changes to its detailed design in order to increase its simplicity, coherence and competitiveness is welcome. In practice, for complex entities and groups, it can be difficult to apply these rules (for example on the question of trading or the impact of prior reorganisations on the availability of the SSE) so any simplification is to be welcomed. It would be particularly interesting if the SSE were extended to investment as well as trading companies.

The Budget has sounded the death knell for the award of "employee shareholder shares" to senior employees: why sacrifice potentially valuable employment rights (and pay income tax on the initial value over £2,000) in the hope of saving (20% x £100,000) = £20,000 …or only £10,000 if the shares would qualify for the newly-extended Entrepreneur's Relief? That said, the timing of the capping is unfortunate for those who have been invited to enter into, and taken professional advice on, an ESS agreement which, because of the 7-day cooling-off period, will not have effect until after 16th March!

Given their recent court victories (Glasgow Rangers and UBS/Deutsche Bank), HMRC have a new-found confidence in tackling tax avoidance, and the changes to "disguised remuneration" rules will allow final recovery of tax on bonuses paid by loans from an EBT. There is however an element of retrospective taxation when tax is charged on a pre-2011 loan remaining outstanding after April 2019 and settlement of tax on the original contribution has not then been made. Withdrawal of the (valuable) transitional relief if settlement is not made by November 2016 will also produce double taxation and is a powerful "carrot" to settle.

Once again the Chancellor was full of surprises yesterday. You could almost hear the jaws dropping with the announcement on capping the employee shareholder share exemption although maybe the biggest surprise is that it has taken so long to make that change. Generally though, the changes appear to lack any sense of consistency or attempt to improve the coherence of the tax system. The combination of the unexpected reduction in CGT rates and the already announced increased in dividend rates will drive people to try to extract profits as capital rather than income which is probably not the desired effect. It is also concerning that the Government appears to be selectively penalising certain sort of activities, so that fund managers and residential property holders will be wondering why their capital gains should be taxed at a higher rate than other people's. Fund managers particularly now live in a complicated world of special rules to determine what is income and what is capital and exactly how their capital should be taxed. On the corporate side there are clearly significant changes to come on interest deductibility and use of losses and no doubt for some businesses these changes will outweigh the corporation tax rate reduction.

Listening to the Chancellor's gloss on the economic situation, I lost interest. As it turned out, the loss of interest was a key business announcement, as was an interest in losses...

Restrictions on interest deductions for large companies, forecast to raise £1bn a year, will disproportionately impact some sectors - certainly real estate (the bogeyman of the Budget, again) and probably private equity. The group ratio rule is critical and must ensure genuine third party debt interest is unaffected. Implementation in 2017 seems like breakneck speed.

The unprincipled tax-grab on large businesses with losses (sorry, modernisation of loss relief), forecast to raise £400m a year, will make it harder for those businesses to recover from the events which caused the losses and may discourage riskier and cyclical investment through the UK. Changes allowing more flexible use of losses were welcome, however.

The reduction in capital gains tax to 20% (except for real estate and private equity of course), coupled with significant widening of entrepreneurs' relief, should attract more fundraising for SMEs. Angel investors and crowd-funders will be pleased, as will smaller investors who would not meet the existing ER tests (mancos, blocked last year, turned out to be trailblazers...). The holding period, two years longer than for ER, will need to be taken into account by business owners.

Finally, the reduction in business rates, whilst not very exciting for tax lawyers, is great news for SMEs. Indeed, it was generally a good Budget for SMEs, at the expense of (some) big business.

The Government is unsurprisingly keen to portray itself as an early adopter of BEPS measures: or at least of the ones that suit it (the rejection of any changes to the CFC rules was notable and equally unsurprising). The new restrictions on interest relief will bring what was perhaps an over-competitive aspect of the UK tax system in line with a number of European systems, although it will be interesting to see if the new rules bite any tighter in practice than existing thin capitalisation rules. The extension of the hybrid rules to permanent establishment structures will probably catch a number of predictable targets, although it does raise the question of why HMRC previously seemed relaxed about such structures. On a similar note, the sweeping away of the rather arcane distinctions between different categories of losses which determine how they can be used will please many advisers (including this one) who struggled to see the logic behind them (and indeed, struggle to remember how they work), but it does lead one to wonder why the Government got so vexed last year at "loss refresher" schemes which did no more than achieve a similar effect. Oh for consistency!

The proposed changes to loss relief. The relaxation of the carry forward rules from 1 April 2017 will make a significant difference to groups. In particular the reform will remove the concern with carried forward losses as to whether a company's activities constitute one overall trade or different trades and the constraint of not being able to utilise carried forward losses against other group member's profits. This relief is, of course, tempered by the restriction on loss offset to 50% of profits in excess of £5 million.

The review of the Double Tax Treaty Passport Scheme is very welcome as there are some procedural issues which prevent the scheme from operating as effectively as it could. Widening the category of eligible passport holders to include certain non-corporates would be a big improvement and relieve some of the difficulties experienced by non UK investors when lending into the UK.

A policy paper issued by HMRC in conjunction with the budget states that legislation will be enacted to give effect to the BEPS final report on transfer pricing from 1 April 2016. The OECD final report on Actions 8, 9 and 10 was issued on 6 October 2015. It is yet to be approved by the OECD Committee on Fiscal Affairs. Their approval is a precondition to the proposals set out in the BEPS final report becoming part of the OECD Transfer Pricing Guidelines. Along with the Diverted Profits Tax, introduced last year, this is another instance of the UK pre-empting the BEPS Project.

The original BEPS Action Plan, which the UK led, observed that "the replacement of the current consensus-based framework by unilateral measures, which could lead to global tax chaos marked by the massive re-emergence of double taxation." The premature introduction of the final report proposals into UK law will put the UK transfer pricing regime out of sync with other OECD member states, and no doubt, emerging economies since the UN tax committee is yet to consider the issue. It will create a headache for UK based multinationals and foreign based companies investing in the UK who will need to have one set of rules for the UK, and one for the rest of the world until the two are brought into alignment.

It is telling that the policy paper observes that the Exchequer impact for the foreseeable future will be nil. Perhaps the reason for this is that, ultimately after time-consuming and expensive, mutual agreement procedures, have resolved resulting double taxation, the UK Exchequer will be back to where it started.

The appearance, finally, of the Government's much vaunted business tax road map shows its continuing commitment, in principle, to working with business on tax policy and will be welcomed by business. Its 2010 predecessor set a positive tone for the relationship between Government and business on tax, as well as containing long-term commitments to structural reform of the tax system - notably the move to a more territorial basis of tax and a system based on lower taxes with a wider tax base. The Government has certainly made good on its promise of lower tax rates, going much further than most expected in making Britain "open for business" with the Chancellor's announcement of a 17% rate by 2020. The reverse side of this particular fiscal deal was, of course, ensuring that all companies pay the "proper" amount of tax and the recent furore over the Google tax deal shows, if nothing else, that public perception is that the Government has still not achieved enough on this front. So, it should come as no surprise that much of the new business tax road map focuses on tackling this issue. As such, the route to be taken between now and 2020 is, perhaps, not quite so scenic as that in 2010. With key drivers being the public finances and deficit reduction, the Government recognises that there will need to be some "difficult trade-offs" and prioritisation, particularly as the UK's tax system catches up with the output from the BEPS Project on controversial topics such as interest restrictions and anti-hybrid rules.

The Government announcement that it will review whether the double tax treaty passport scheme still meets the needs of UK borrowers and foreign investors is very welcome. The consultation, to be released later this year, will also seek to determine whether the scheme, which is currently limited to corporate investors, should be extended to other types of foreign investor, including sovereign wealth funds, pension funds and partnerships. This would be a sensible development, alongside the recent introduction of the private placement exemption. One wonders whether in the longer term there remains much benefit for the UK in retaining an interest withholding tax in light of other changes announced today (such as interest restrictions and restrictions on use of carried forward losses) - although given the Government's apparent attachment to interest withholding taxes, they seem likely to remain with us for some time.

The government is pressing ahead with its response to BEPS. But that conflicts with the different response proposed in the draft EU anti-avoidance directive (notably for the actions on interest deductibility and hybrids)‎. And the EU directive may be passed before HMRC's interest and hybrids legislation even come into force early next year. Political agreement on at least part of the Directive is planned for 25 May, 29 days before the referendum. Is HMRC planning for Brexit, or exerting leverage on the drafting of the Directive? The worst of all worlds would be conflicting rules.

Perhaps the biggest change in respect of real estate taxation is a move to ensure that non-UK resident companies who are trading in or developing UK land will be subject to UK corporation tax on their profits regardless of whether they have a permanent establishment in the UK. Up to now, some companies have structured their operations to make use of the UK's older Treaties with Jersey, Guernsey and the Isle of Man to ensure that the UK did not have taxing rights over their trading profits from the development of UK land. Although the introduction of the DPT put such structures under pressure, the Government has now acted to ensure trading profits from UK land will be subject to UK corporation tax. Although this move was unexpected, it is consistent with the Government's desire to create a more level playing field in respect of the taxation of UK property and marks a further erosion of the territorial scope of UK tax on real estate that began with ATED and continued with the extended CGT charge.

The fall in capital gains rates is clearly good news for our area, which despite all its critics, continues to be supported by the tax system while partnership carry has been aggressively attacked over the last few years. Starkly showing how tax-favoured share plans have now stabilised and become a mature product, the specific news in this Budget on employee shares comes from outside employee share plans. Although the new £100,000 limit on Employee Shareholder Shares tax-free gains is detrimental, it just shows how well-supported the area continues to be. It was predicted at the outset that the ESS legislation was going to be a great success for different reasons than the stated Government policy, and so it has proved. It has now become considered in virtually every private equity transaction. While the limit is perhaps smaller than might have been hoped, it still allows a 50 x gain to be received tax free, and, perhaps best of all, the cap does not apply to the many arrangements already in place. It remains to be seen whether the setting of the cap at this level materially reduces interest in these arrangements. Will the upfront costs worth a maximum of £20,000 saving per arrangement still make clients interested in them? We think so, but only time will tell.

Obviously a bitter-sweet Budget for business with the changes outlined in the Road Map likely to affect them. Given that many of the changes are likely to come in next year, we need to see the details as soon as possible, both in general terms and also how they will affect particular industries, such as the banking and the insurance sectors. Outside the headline areas, I was very pleased to see that the Government will introduce enabling legislation for Insurance Linked Securities (ILS). This follows very quickly on the Treasury Consultation Paper and is to be welcomed - although HMRC will have a difficult task balancing tax neutrality and anti-tax avoidance.

The publication of the business tax roadmap has the laudable aim of giving certainty to businesses. But it also announced two interesting reviews that are yet to be conducted.

First, the consultation on the substantial shareholding exemption to gauge whether it is meeting its goals of ensuring that tax does not act as a disincentive to commercially desirable business sales or group restructuring, and to ask whether it could be amended to make it simpler, more coherent and more competitive in the international tax landscape. By comparison with similar exemptions in other countries, the SSE is unusually complex and laden with pitfalls. Any kind of simplification, especially in relation to the "trading" conditions, would be hugely beneficial in improving certainty and reducing the volume of detailed analysis and/or clearance applications.

Second, the consultation on the Double Tax Treaty Passport scheme to ensure that it meets the needs of UK borrowers and foreign investors, and to determine whether it should be extended to other types of foreign investor, such as sovereign wealth funds, pension funds and partnerships. Although treaty relief can often be achieved for many investors, it is encouraging to see the government's open support for debt-based investment management activity in the UK. Together with the new withholding tax exemption for private placements, the administrative burden for obtaining relief on loans to UK borrowers could be significantly reduced.

The CT rate is reduced to 17% but large business is regarded as the big loser. When I started out in tax the rate was more than three times higher.

The interest barrier is pretty much as expected; and it is less severe than it could have been. But the WWDC is to be built into it in a sneaky way (it looks like a tougher WWDC) and it is a shame that so much uncertainty remains about the detail. The new IP royalties WHT regime is an old fashioned but understandable host state response to BEPS activity and it must have been tempting to have a go at it before now. The interest WHT regime remains unchanged, in an incoherent and weaker state, but perhaps there has been enough interest bashing already. The loss relief restrictions feel harsh - an unwelcome companion to a response to requests for a more flexible regime for the use of losses.

Overall, this is a considered shopping list from HMRC which contains tweaking to both prevent perceived abuse and gives some help to taxpayers. The proposed changes to entrepreneurs' relief do both these things. The most interesting proposal is the new rules to tax trading profits derived from land in the UK. This is aimed at structures which essentially seek to shelter such profits using treaties. These structures are already under pressure, including from diverted profits tax, but HMRC obviously feels it needs this additional tool. HMRC say the legislation will rely on the treaty preserving the UK's taxing rights over UK land. The Guernsey, Jersey and Manx treaties are amended from Budget day to comply with this. Doubtless, there will be scope for argument on older treaties where the UK cannot force an amendment. But meanwhile the reduction in UK CT to 17% further reduces the benefit of such structures in any event.

From the point of view of the North Sea oil industry (or at least most parts of it), it's three cheers for the Chancellor in acceding to their calls for help in their present very difficult circumstances. The effective abolition of petroleum revenue tax and the halving of the rate of supplementary duty means that all North Sea profits will now be taxed at 40% (as compared with rates from 62% to 81% just 18 months ago). The truth is that it hasn't really cost him much at all, since hardly anyone in the industry is paying tax at present as a result of the persistently low oil price, but the changes at least provide some encouragement to further investment in what is still a key industry for the UK economy.

At the technical level, the Government has also recognised, in the context of late life fields transfers, that there has been some uncertainty over the working of the capital allowance subsidy rules as to whether a seller who agrees to retain the liability to meet decommissioning costs would obtain full tax relief on those costs. As part of the Budget announcements, HMRC have published a welcome policy paper clarifying their views on what conditions will need to be met for relief to be available. All in all, the package provides the industry with some light in the gloom.

In other respects, especially in relation to the changes for non-resident developers of UK property, the Chancellor seems to be maintaining some consistency in bearing down on differences in tax treatment of non-residents doing business in the UK as compared with the tax treatment of UK residents doing the same thing. Perhaps the small businesses in Crickhowell who won the publicity from threatening to "go offshore" can get some credit for shaming the Government into introducing some of these measures."

Although billed as limited in scope, this budget proposes some fundamental changes to the UK tax system intended to take effect in a worryingly short time. The scale of these changes combined with the planned timetable is likely to have a destabilising effect on business.

Key measures include the unexpected change to the loss relief rules for large companies as a result of which only half of their taxable profits can be sheltered by carried forward losses. Although accompanied by enhanced flexibility on loss utilisation across businesses and groups this change is expected to be a significant revenue raiser. Labelling it as a modernising measure seems a little disingenuous. Of particular concern is the lack of detail for something so significant and the fact that the changes are to apply from 1 April 2017. Equally fundamental is the proposal to limit relief for interest costs for UK groups. Although the subject of recent consultation, there are real areas of uncertainty here not least the fact that applicability of these rules to banking groups is still to be addressed. These rules are intended to apply from April 2017 and no grandfathering is expected. A further major measure is the decision to implement new anti-hybrid legislation with effect from 1 January 2017 again with no grandfathering. Draft legislation was circulated in December last year together with guidance. There is real confusion about how these rules are intended to apply and they contain untested concepts which need more clarification. It is hard to see how taxpayers can begin to properly plan for these rules and to self assess their application in such a short time.

Although understandable that the UK wants to be seen as a leader in implementing BEPs recommendations, there must be some concern at the speed at which this is being done.

There is more to see in this Budget than expected, but it is a Budget of sticks, carrots and tambourines. Of carrots, there is much to admire - the cut in CGT rates (unless you are a fund manager or a second home owner, in which case tough luck), the extension to entrepreneurs' relief to external investors, the extension to the DTTP scheme. But beware the sticks - they are having another go at single person companies, they are about to hurry the new interest deductibility rules through to commence April 2017 (everyone brace for some really bad drafting - especially as the worldwide debt cap dies and rises zombie-like in a new form), and having a stab at royalty withholding tax. On tambourines, will increasing the "simplicity, coherence and international competitiveness" of the substantial shareholding exemption be code for "it's working, let's mess it up?" - I hope not (but hope springs eternally disappointed). And of special interest, watch the sleight of hand as the Chancellor improves the useability of carried forward losses arising post April 2017 whilst restricting all those lovely losses carried forward from the bad years - sorry, chaps, it's shadow ACT all over again.

Predictably, the Chancellor has delivered a Budget that appears to be entirely consistent with two fundamental objectives: to raise money to bring down the deficit and to move the Conservative government into the centre, even possibly centre-left,‎ political ground. Whilst there were some welcome measures for all business, such as the further reduction in the rate of corporation tax to 17 per cent, for the most part the positive measures (for example in relation to business rates) were targeted at smaller businesses, whereas larger businesses did not fare quite as well (for example with restrictions on the amount of profits against which carried forward losses may be set).

The property sector was arguably hit hardest, though, with the SDLT rate increase from 4 per cent to 5 per cent for commercial property purchases, the supplemental 3 per cent SDLT on additional residential property purchases applying to individuals and companies alike and no indication that the proposed restrictions on interest relief to 30 per cent of earnings before tax would not apply to property investors.

Now that Claudio Ranieri has discovered the benefits of continuity it seems that George Osborne is the true tinkerman, unable to let well alone.

Admittedly he had to do something for the oil and gas sector and the effective elimination of PRT is particularly welcome, though making any profits at all is currently a challenge in the North Sea; and three of the four changes to entrepreneurs' relief reflect a failure of implementation (when the relief was pruned back last year) rather than of policy, though this suggests that improvements are needed to the legislative process. But why increase IPT first to 9.5% then to 10%? The divergence between the rates of tax on income and capital is also remarkable - but perhaps explains why HMRC is already consulting on amendments to other parts of the tax code designed to make it more difficult to turn one into the other.

There are important changes for the property sector too (to say nothing of the announcements relating to mainstream corporation tax). I won't myself be sorry to see the end of schemes aimed at escaping corporate tax on property development, while it was perhaps inevitable that SDLT on commercial property would creep upwards now that the effective marginal rate at the top end of the residential market is in many cases 15%.

The property industry will be left reeling after a Budget that included the triple-whammy of a rise in SDLT rates for residential property and high value commercial property, the prospect of restrictions on deductibility of interest and the taxation of offshore property trading companies.

The big surprise was no exemption for large scale investors from the additional 3% SDLT rate on residential property acquisitions, despite the Government previously stating its support for investment in the private rented sector. It looks as if this U-turn was driven by a desire to raise revenue and not wishing to be seen to offer preferential treatment to large businesses. However, the additional 3% rate will have a significant impact on the returns that might be available from investment in residential property and is likely to discourage the growth of the build to rent market.

The taxation of offshore property trading companies builds on the impact of the Diverted Profits Tax and will increase the trend towards using UK companies as the vehicle of choice for UK property development.

In a big boost for the AIM market, the Budget introduced a reduction in the CGT rate to 10% for gains on disposals of shares in unlisted trading companies (effectively an extension of the existing entrepreneurs' Relief to investors).

This is effectively a 50% relief (ie a reduction in the CGT rate for higher rate taxpayers from 20% to 10%) and should encourage investment into companies admitted to trading on AIM (which will presumably continue to be treated as unlisted) and private companies.

A complex Budget, with much to digest. It had already been announced that the Office of Tax Simplification is to be put on a permanent footing. This Budget ensures they won't be short of work.

It is unsurprising that our hybrid mismatch rules will end up diverging a little from the recommendations in the OECD's final report - although less expected that HMRC appear to have singled out permanent establishments as the only area for change. The high-level announcements on interest deductibility were largely as anticipated. It is welcome news, however, that the worldwide debt cap will not be retained as a separate regime.

How long before we see some of the changes on royalties withholding (the clarification of the "source" of payments by a UK PE of a non-resident, and the domestic override of treaty withholding exemptions in the case of connected party "treaty shopping") being applied also to interest payments?

I was surprised at the modest yield projected for the curtailment of the CGT benefits of Employee Shareholder Status (£10m in 2019-20 and £35m in 2020-21), even making allowance for the reduction in CGT rates and potentially also the extension of entrepreneurs' relief. A genuine underestimate of the extent to which this was being used - or was someone sparing the Chancellor's blushes?

The pre-Budget chat on pensions went from one extreme to the other - the anticipated pensions revolution was dropped in favour of what seemed to be a leave well alone strategy. It is perhaps no surprise, therefore, that what we have now got is something of a mixture of the two. No change to the current regime for pensions tax relief is the big news. However, the introduction of the new Lifetime ISA marks what looks like the start of an entirely new approach to long-term savings - a revolution in other words. It is early days, but there is no escaping the conclusion that we are now looking at an early prototype of a new pensions model.

The risks are evident. Once the new Lifetime ISA is up and running, long-term savers will need to make some difficult calculations about what is right for them, namely pensions or ISAs. Employers too will need to pay close attention to what their employees want by way of a savings benefit. The traditional model may well come under some strain, particularly if the early prototype of the Lifetime ISA proves to be a runner. In that case, it would be a simple matter for the Government to shift the tax incentives away from pensions and into ISAs.

On other matters, it is welcome that salary sacrifice for pension contributions looks safe, and it is good that the Government wants to bring greater coherence and efficiency on the financial advice regime available to pension savers.

On public sector pensions, the reduction in the scheme discount rate and consequential increase in contribution requirements will put pressure on employers at a time when they are already feeling squeezed by pressure on their budgets (not to mention increased NICs costs). As the cost of delivery of public sector pensions comes under increasing scrutiny, perhaps this change to the discount rate is another early indicator that a traditional model is coming under strain.

The Budget was full of surprises for those in the real estate sector. Apparently under pressure from backbenchers, the Government offered no exemption to the increased second home SDLT rates for large scale investors in residential property. This was particularly unwelcome for institutional investors in the private rented sector market where, to date, they have successfully used multiple dwellings relief (MDR) to mitigate SDLT exposure. MDR remains but will be far less attractive. If six or more properties are acquired in one go the default commercial rate of SDLT may result in a lower rate. The Government also announced a new slab system for commercial SDLT and increased rates to 5% for consideration over £250,000 plus a 2% rate on leases on any NPV over £5m. The rates change from 17 March 2016 unless the transaction has exchanged before then. This seemed particularly harsh especially as this was not an anti-avoidance measure.

The Government is also planning to bring in legislation from Report Stage of the Finance Bill 2016 to tax profits from the development of UK land regardless of the residence of the owner or whether a trade exists. This measure attacks off-shore structures which are set up and managed so that they do not create a trade or permanent establishment in the UK.

The Government confirmed that the restrictions on corporate interest deductibility arising from BEPS Action 4 will come into effect from April 2017. We still have uncertainty on some of the details including the scope of the public benefit exemption which will form part of a further consultation later in the year. There was notable silence in relation to grandfathering provisions, which might suggest that the Government will not exempt existing debt from the new rules.

For me as a corporate tax practitioner, a single breathtakingly appalling decision overshadows all else in a surprisingly technically dense Budget. This is the extraordinary announcement that the new BEPS based interest restriction will be introduced in April 2017.

This is one of the biggest and most potentially complex changes to the structure of our corporation tax regime for many years. It is a reversal of a previous openly stated policy to be generous with interest relief in order to attract business to the UK. And as with so many other announcements its presentation in an anti-avoidance context is deeply disingenuous, designed only to paint critics as friends of tax avoiders whose views should be discounted accordingly.

Two things follow inevitably from this timetable. Firstly, businesses will have very limited time from the eventual publication of draft legislation to consider its impact and perhaps adjust their funding arrangements. This flatly contradicts the OECD's own report recommending the measure which stated that businesses should be given a reasonable time to adjust to the new rules. Secondly, and even more seriously, it means that the measures will take effect before the legislation implementing them hits the statute book. In a properly run constitutional democracy, this should be unthinkable.

Other observations: this timetable seriously calls into question the bona fides of the consultation process. Given that the first question asked was when the measures should be implemented, and given that all the many representations I have seen on this subject agreed that April 2017 was unrealistic, why was this question even put if those recommendations were doomed to be ignored? How will we ensure that our group ratio rule is consistent with the OECD recommendation, when that recommendation won't be finalised until later this year? And finally given the recent record of the Government in drafting legislation to short timetables, how can we have any confidence that when published the legislation will be well put together?

Much good work is being done to improve the UK's tax competitiveness, but this is a potentially huge step in the wrong direction. There is no reason for the unseemly haste: other countries are biding their time (and presumably giggling at the spectacle we are making of ourselves). The constitutional issues raised are profound. All concerned in choosing this timetable should hang their heads in shame.

In some respects a frustrating Budget, light on detail for some of the key forthcoming measures (e.g. changes to loss relief rules) and, where there is detail supplied, at times perplexing in approach. In the CGT world we have the extension of entrepreneurs' relief to long term investors, many of whom, one would imagine, would prefer if at all possible to benefit from the exemption from CGT for holding shares for three years under SEIS or EIS. Staying with entrepreneurs' relief, there is a winding-back of last year's anti-avoidance measures to prevent the use of "Manco" structures to access greater levels of relief using the deemed JV trading company rules; the problem of genuine management investors in joint ventures is ostensibly addressed (retrospectively) by the new changes, yet the requirement to have held 5% directly or indirectly in the joint venture company itself will still exclude many managers holding 5% in a JV partner under quite legitimate and non-tax motivated structures.

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