Osborne wants to turn the UK into a tax haven by the standards of some foreign jurisdictions. For example, Brazil's new CFC legislation will apply to prevent fiscal consolidation for UK subsidiaries from 2017, when the corporation rate drops below 20%. This measure will also have the effect of lowering the UK CFC and DPT thresholds.

Strikingly (and deliberately (?) not covered in the speech), the taxation of PE fund managers looks a little ringfenced from a policy perspective. The government's consultation on use of carried interest schemes by those other than proper private equity, whatever that is, seems a little artificial: the traditional investment/trading distinction is seemingly not enough to create the correct tax outcome any more, for HMRC's purposes at least. The suspicion of an eventual DIMFR-like regime (it's all taxed to income unless we legislate otherwise) is high.

In contrast, the death of basis shift for PE managers will be a blow between the eyes that they will find hard to argue with philosophically, and may send another little message to the US which is considering its own approach to the topic, that carry taxation is not regarded as sacrosanct. The BVCA is clearly rattled, initially engaged in "intense" discussions with HMRC but now recognising the fait accompli.

Although offset to an extent by the proposed further cut in corporation tax rates and increase in the employment allowance, the income tax rise on dividends will remove some of the tax advantages currently enjoyed by company owner managers who pay themselves significant amounts by way of dividend. Such individuals will be thankful, however, that, despite pre-Budget rumours to the contrary, the Chancellor has left the CGT regime (and Entrepreneurs' Relief in particular) relatively untouched. Another notable change affecting SME's is the previously unannounced restriction on the use of EIS and VCT monies to acquire existing businesses, regardless of whether that is through a share purchase or asset purchase. Disguised employment continues to be in the spotlight, with the government promising a consultation on possible reform of the IR35 rules amongst other measures aimed at targeting the avoidance of employment taxes. Finally, it is indeed to be hoped that the announced consultation on the tax and NIC treatment of termination payments (one of a number of simplification proposals involving NICs) will "make the system simpler and fairer".

A "forward-looking" Budget in the most literal sense - anti-avoidance apart, most of the announced changes are to have effect from 2016 or even later years. This is welcome, in that it allows businesses time to adapt. The promised "business tax road map" is also welcome. However, whether the desired result of encouraging long-term investment will follow is debatable - it is arguable that a stable, even if less attractive, tax environment will do more to promote this.

The so-called "tax lock" will be incorporated in legislation but its effect will be largely political: like all legislation it will be able to be amended or repealed but the political cost of doing so may be greater and more apparent. The Budget has set the corporation tax rate for the life of this Parliament: the "tax lock" will do the same for income tax VAT and NICs, but with more fuss. What is the point?"

Non-doms were Labour's only General Election "redline" issue. However, those who expected Conservative victory to mean the status quo, should have read the runes better. Although there will be dire warnings of threats to UK competitiveness, it should have been apparent that the non-dom rules were set to change. I will go out on a limb and say that the proposed changes are sensible and, if implemented properly, promise to put the non-dom issue to bed for the immediate future. Sensible? While it is sensible to encourage wealthy foreigners to come to the UK, the current system is not fit for purpose. Domicile is the wrong definition of "wealthy foreigner" and the remittance basis encourages those who come to leave their money behind. I had hoped for wider reform, but that is a step too far at the moment: I suspect it may follow next Parliament. If implemented correctly? There is a sensible 2 year transition and a promise of consultation. That consultation needs to:

A highly political budget seeks to balance welfare cuts with an increase in the minimum wage and some hits on the wealthy. The change to the treatment of long term resident non-doms ends one of the longest running debates on tax policy - at least for a while. The reduction in tax relief for buy to let landlords is a surprise that may have uncertain effects in the market. Investment in more technical resource for HMRC is a welcome development but one may be sceptical whether it will deliver the several billions in additional tax from counter-action of tax avoidance that is predicted. The reduction of corporation tax continues a trend which benefits companies but with detailed changes (eg, to purchased goodwill) which extend the tax base, and which, on government estimates, is more than offset by the increase in tax liability for their shareholders through the abolition of dividend tax credit.

As widely predicted, this was an active Budget.

Banks and residential property owners are likely to feel quite aggrieved. So far as the banks are concerned, whilst the reduction in the rate of bank levy will be welcome, the new 8% surcharge on profits will not, particularly as the profits which are subject to the surcharge cannot be reduced by any relief arising before 1 January 2016 or group relief from any non-banking company. The proposed reduction in corporation tax rates also means that the value of carried forward losses dating from the financial crisis, already depleted by the restriction placed on the use of those losses in the last Budget, will be further reduced. When taken together with the acceleration in corporation tax instalment payment dates, it is a pretty unhappy package for the banks.

Landlords of residential property will also be unhappy. Relief for their finance costs is to be restricted to the basic rate and the 10% deduction for wear and tear in relation to furnished properties is to be abolished.

Other measures of interest were the announcement that a voluntary code of practice defining the standards that HMRC expects large businesses to meet in their relationship with HMRC is to be introduced, the proposed consultation on the rules for company distributions in Autumn 2015 and the legislation preventing the base cost shift which is of such benefit in carried interest partnerships.

Overall, many of the measures seem reasonable and it will be interesting to see how the Budget fares in the court of public opinion!

As this was his first Budget without the interference of those pesky Liberals, I suspect the Chancellor was keen to lay down a marker. With the details of DPT still confusing the best of HMRC and the wider profession, and BEPS implementation likely to consume resource for years to come, the rebasing of parts of the tax system allowed the Government to shape a strategy for the next five years. Lowering the corporation tax rate seems to be a popular measure, but as ever the financial services sector is being asked to pick up the slack with the introduction of the 8% bank profits surcharge (with gradual reduction in the bank levy) and the increase of the standard rate of insurance premium tax to 9.5%.

The usual diet of anti-avoidance rules continue with new restrictions on use of losses with CFCs and further proposals on penalties for schemes falling foul of the GAAR. Another interesting point to note is that, as well as implementing the Common Reporting Standard in the coming months, HMRC will phase out tax returns and introduce tax accounts with data already populated from various sources. One wonders if HMRC really have the resources and expertise to do this, and one should expect some teething problems!!

There were a notable number of developments to welcome in the Summer Budget. The larger banks are likely to welcome the reduction in the bank levy and the predictability which should come with the bank levy rate being set for the term of this Parliament. Previous Government policy appeared at times to be to set the bank levy rate in tandem with the degree to which public hostility towards the UK’s banking sector was evident through the media (and presumably opinion polls). With banks' balance sheets being reduced, and fewer liabilities resulting in higher profits, the Government's introduction of the corporation tax surcharge for banks is unsurprising. Whether the change will be sufficient to discourage threatened bank re-domiciliation from the UK remains to be seen.

The new section 323A CTA 2009 corporate rescue exemption will be warmly welcomed and should be of significant practical use in the debt restructuring of companies in financial distress. The introduction of the new exemption should reduce the temptation to shoehorn restructuring transactions into the debt-for-equity swap legislation. The new exemption is one of the crown jewels of HMRC's lengthy public consultation on loan relationships and derivatives, and stands as testament to the exemplary way HMRC have approached that consultation.

As one exemption is created, another tax benefit (in the form of the base cost shift for carried interest holders) ends abruptly. The announcement of the change, and the absence of grandfathering provisions, indicate that the Government has the asset management and private equity sector under the spotlight. As with the "loss refreshment" legislation announced in the March 2015 Budget, the carried interest tax planning now being counteracted is long-standing and commonplace, and would not be prevented by the UK's general anti-abuse rule. One suspects that the changes announced are a shot across the bows of the private equity sector; with a generally unsympathetic media environment for any tax planning, the Government is nothing if not adept at choosing its targets.

George Osborne said his second Budget in 2015 would be a "Budget for working people" and, to be fair, it most probably is as many of the tax rises - the restriction of finance costs for landlords, the reform of the wear and tear allowance, the changes to the taxation of dividends and the abolition of non-domicile status for long domicile residents to name but a few - will fall on those who generate funds from investments. This is particularly true in the case of the changes to dividend taxation as individuals whose income consists primarily of dividend income will typically be worse off, while the main group of winners is likely to be employees who are taxed at 40% as the £5,000 annual dividend allowance should result in a tax saving. It is, also, interesting to note that no further attempt was made to tax carried interest as employment income.

The reduction in the rate of corporation tax is to be welcomed and could see an increased move from trusts to companies for estate planning purposes in spite of the dividend taxation changes.

A mixed bag for the City and a few surprises:

For businesses other than banks, the corporation tax position seems broadly positive. The unexpected cut in rates of corporation tax will of course be welcomed, as will the business tax roadmap to be published by April 2016. Both should reinforce the government's commitment to international competitiveness. In that vein, it will be interesting to see whether, and how, the roadmap deals with the implementation of BEPS, in particular to avoid future surprises like the diverted profits tax. The reduction in rates may in part be intended to neutralise adverse consequences from BEPS implementation, such as reducing the scope of the patent box.

However, large UK businesses are also being asked to shoulder more of the burden of achieving the government's targets on deficit reduction, with the introduction of the national living wage, the levy on businesses to pay for apprentices, and the bringing forward of corporation tax instalment payment dates. The suggestion of a voluntary Code of Practice for corporates is also a double edged sword. It might be a useful tool for businesses looking to manage their tax reputation, but previous experience with the equivalent bank code suggests that it may not remain truly voluntary for long.

The reduction in the rate of corporation tax to 18% is not all good news for individuals operating through personal service companies. After 6 April 2016, the removal of the notional tax credit to account for corporation tax already paid on a company’s profits, originally designed to avoid double taxation, will mean that individuals will pay more tax on taxable dividends. No doubt companies will be looking to pay out healthy dividends before April 2016 - which must be good news for the Conservatives' likely tax receipts for their first year back as a solo act.

The abolition of the dividend tax credit is not simply a reform of an "arcane and complex" part of the tax system but a major revenue raiser, forecast to bring in over £2 billion in 2016-17. The scale of the projected tax take suggests it will affect far more individuals than holders of large investment portfolios, and will apply to owners of medium and some comparatively small businesses who operate through a company. Business owners may be minded to seek an exit where they can obtain entrepreneurs' relief.

Ominously, a consultation will be released in Autumn on dividend taxation so the Government clearly has other changes in mind. It would be appropriate for the consultation to include proposals for a regime to allow tax neutral disincorporation of businesses where a company is no longer appropriate following the dividend changes.

The raft of changes to the UK tax rules impacting investment managers continues. The preferential UK tax treatment of carried interest is being withdrawn with immediate effect (including for existing arrangements). Returns on carry can still attract capital gains treatment for the time being but the "base cost shift" which gives carry holders a share of the initial investors' base cost is being removed such that carry holders will now pay full CGT on everything they receive as carry. Non UK domiciled carry holder can still elect to be taxed on the remittance basis but will need to consider their domicile status in light of the changes to the rules on domicile. In addition the government is consulting on the extent to which carried interest should be subject to capital gains tax rather than income tax. This is aimed at denying capital treatment to some alternative funds rather than traditional private equity funds although the proposals could impact traditional funds

Definitely a radical budget, with sufficient measures against hedge fund managers, banks, non-doms, buy-to-let investors and large corporates to head off too many accusations that the rich have "got away with it" whilst the lower paid suffer cuts in welfare. Keeping the planned introduction of the "national living wage" secret until the day itself was almost as remarkable as the radical nature of a budget to improve wages and lower taxes and welfare.

There was also the usual rhetoric on tackling avoidance and evasion - but very little detail. An extra £750m was committed to building HMRC capacity, coupled with an increased focus on wealthy individuals, public bodies and mid-sized corporates - along with "special measures" for large corporate who continue to engage in aggressive planning strategies. There was no detail on the corporate offence of "failure to prevent the facilitation of tax evasion" which has been concerning banks and other companies (consultation awaited) - nor the result of the consultation on the "single issue" closure notice procedure, and whether HMRC will yield to the pressure to make this a two way rather than "one-way" power.

So far the Chancellor is approximately two thirds of Nigel Lawson - taxes are, generally, a bit lower (see further reductions in corporation tax and increased income tax thresholds), and are most definitely viewed as compulsory (see increased funding for HMRC to go after evasion and avoidance, and the usual slug of "anti-avoidance" rules). Unfortunately there isn't much simplification so far (though it is encouraging to see the OTS being put on a statutory footing) and the stated intention of going after behaviour that amounts only to tax "planning" is a bit disturbing.

From the personal tax measures the non-dom announcements will probably get many of the headlines, but the changes to treatment of carried interest in fund structures are dramatic and immediate. The timing of the latter measure has presumably been justified by categorising it as clamping down on avoidance, which seems rather unfair given the history of the previous treatment. The combined effect of these two changes could be some very unhappy fund managers.

On the corporate side, the phasing out of the bank levy seems obviously intended to keep the likes of HSBC in the UK. Further unexpected corporation tax rate reductions will clearly be welcomed by business, though it remains to be seen whether these will be accompanied by (for example) reductions in capital allowances rates in due course, and for some companies part of this benefit will be swallowed by increased employment costs. Conversely, the withdrawal of relief for purchased goodwill amortisation is unwelcome, and bound to affect ongoing transactions.

From an employee benefits perspective, it was the Chancellor's statement that he is "open to further radical change" in pensions taxation which was perhaps of greatest interest. The consultation on pensions tax relief sets out a number of proposals, ranging from fundamental reform (akin to the taxation of ISAs) to less far-reaching changes. Clearly, much will depend on the responses to the consultation, and it remains to be seen just how radical the government is prepared to be in tackling this complex area.

The government has confirmed that the Office of Tax Simplification (OTS) is to be established on a permanent basis, with an expanded role. As a number of their recommendations have already led to fundamental changes (such as the move from formal HMRC approval of share plans to self-certification), their forthcoming review on the thorny subject of the closer alignment of income tax and NICs is awaited with interest.

The changes to taxing dividends will have a significant impact, particularly for recipients of dividends from private businesses and large investment portfolios who will see their tax rate increase. Whilst the Chancellor has sought to revitalise what he says was an "archaic" dividend tax regime, the proposed changes discourage entrepreneurial activity and enterprise at a time when we need to incentivise small businesses and encourage growth in the UK economy.

The Chancellor was not expected to match Labour's election promise to abolish permanent non-dom status for anyone resident in the UK for 15 of the last 20 years so this announcement has come as a surprise. Whilst it is encouraging that the non-dom regime has not been abolished in its entirety, the changes are significant and will drive new behaviour. Anyone born to a British parent can no longer qualify. We expect this will capture a large proportion of those currently enjoying non-dom status who will now need to consider their tax liability. For those not of British lineage, going forward they can retain non-dom status but only if they ensure they are non-resident for a few years at a time. This proposal is likely to lead to a number of non-doms exiting the UK.

The Summer Budget contained a surprise measure to restrict corporation tax relief for business goodwill amortisation. The measure will prevent corporation taxpayers from claiming tax relief for goodwill acquired on a business acquisition in relation to accounting periods beginning on or after 8 July 2015.

The premise is that the measure will prevent distortions between the tax benefits of an asset acquisition compared to a share acquisition where no such tax relief is available. To quote the HMRC's press release, "Removing the relief brings the UK regime in line with other major economies, reduces distortion and levels the playing field for merger and acquisition transactions." True enough, although it is rare that a deal is ever structured as an asset acquisition based principally on the purchaser obtaining amortisation relief for goodwill. There are plenty of other factors in play, such as not wishing to take on a corporate target's liabilities on a share acquisition which might drive a purchaser down the asset acquisition route.

As expected, there was little in today's budget which was specifically directed at employee share plans. However, in particular with recent changes to the pension regime, there has been more focus from employers on the role of share plans within the wider remuneration and benefits package. Employers will be interested to track the consultation on pensions tax relief and should note the restriction on pensions tax relief for high earners. The impact of share plan income pushing employees into higher rates of tax and potentially into brackets where tax reliefs (personal allowance and/or pension tax relief) are restricted will be relevant considerations.

The clear message from the Budget was a desire to level the playing field - entrepreneurs cannot benefit from extracting dividends from their companies at significantly more favourable rates than receiving it as remuneration through the abolition of the tax credit and the introduction of higher dividend tax rates; successive reforms now extending to inheritance taxes resulting in non-residents no longer being able to benefit from holding UK residential property in comparison to UK residents; private equity managers no longer benefitting from base cost shift on their carried interest and aligning them with other shareholders. However, a surprising announcement in levelling the playing field is in the area of share and asset purchases, where the removal of the benefit of tax relief for amortisation of goodwill and customer related intangibles acquired after Budget Day will result in share transactions being favoured even more in future.

We welcome the unexpected reduction in corporation tax rates which will enhance the competitiveness of the UK and the reform to the loan relationship rules on debt releases which will facilitate the restructuring of companies in distress.

The first Budget of the new Government felt very significant: there are some major tax rises and changes to the welfare provisions. There was a "give and take" feel about the Budget and in places it felt like the Chancellor was trying to strike a deal with sections of society and business: the National Living Wage being offered in return for welfare reform; and business benefitting from corporation tax cuts in return for having to provide higher wages. The revenue raising measures are spread quite widely: the IPT increase will be felt by many as will the dividend changes, the well-trailed reduction in pension relief and the surprising hit on the buy-to-let sector. Banks are also being asked to contribute again, although the surcharge in return for the reduction and reform of the bank levy will seek to persuade banks that moving headquarters from the UK is not the answer. There are also other points of interest for the corporate tax practitioner: the abolition of corporation tax deductions for the amortisation of goodwill and CFC changes being obvious ones.

The Budget was a mixed bag for business. On one hand, the Chancellor was keen to show that the UK is "open for business" by reducing corporation tax rates and apparently recognises the need to provide certainty (through a new "business tax roadmap"). However, other measures underline the fact that the UK's tax regime is subject to constant change as there were significant departures from long standing positions in a number of areas (notably, acquisitions of goodwill, utilising losses against charges under the CFC regime, the treatment of carried interest and the position of "non-doms"). After the cuts to UK North Sea tax rates in March, the oil and gas industry will be disappointed that the Chancellor did not take the opportunity to push forward further measures to regenerate the UK North Sea, including incentives for new entrants and early stage exploration companies.

The headline rate of corporation tax is just that, a headline. And it makes great headlines - emphasising the Conservative party's pledge to make the UK a great place to do business (the fact that the "surprise reduction" is fully funded by bringing forward the quarterly instalment payments dates isn't a headline, but it is rather clever).

The Government plans to introduce a "special measures" regime to tackle large business as well as a Code of Practice to define standards HMRC expects large businesses to meet in their relationships with HMRC: it is hoped that these measures will be clear with due regard to input provided to HMRC during the consultation period as that will ensure a spirit of cooperative compliance which will further enhance the UK's status as a leading business destination and minimise unnecessary disputes in due course.

On the contentious tax front, a quiet budget. Although whether the increase in the differential of rates between Corporation Tax and Diverted Profits Tax will act as a motivating factor for challenges to the latter remains to be seen.

The controversial "direct recovery of debts" measure, which enables HMRC to secure payment of tax debts directly from bank accounts, will be introduced and will have effect on and after the date of Royal Assent of Finance (No 2) Act 2015. Draft secondary legislation will be published alongside. HMRC estimate that the measure will be applied to around 11,000 cases per year, and that approximately 200 objections will be generated each year. Although some of the concerns that were raised during the consultation process have been addressed (such as by introducing a right to appeal to the County Court and seeking to protect "innocent" joint account holders, by ensuring that joint accounts always have a lower priority than other accounts), an undesirable consequence of the measure - that it has the potential to make HMRC a de facto preferential creditor - remains.

The CGT base cost shift was an unintended quirk of the partnership legislation, and so its abolition does not surprise me. It was a legitimate tool for reducing the effective tax rate on carry returns, however, and I therefore find it disappointing that its abolition will apply without any grandfathering for existing carry structures. Introducing measures like this without warning undermines confidence in the Government's willingness to create a stable fiscal regime for businesses.

In contrast, the announced future reductions in the corporation tax rate seem to be positioning the UK for the post-BEPS business environment where local substance will be key. This is sending a clear signal to multinational companies that a favourable corporation tax regime should remain on the UK's list of attractive features when deciding where to establish real physical presence.

When the Code of Practice on Taxation for banks was introduced in 2009, there was a suspicion among some that it would be extended to large businesses over time if it proved successful. Sure enough, this seems close to realisation now, with the consultation on a voluntary Code of Practice for large businesses. The banking Code of Practice started out as voluntary, remember. Expect large businesses to be named and shamed if they do not sign up to the Code of Practice within a few years...

Of note is the continued focus on the investment management sector. The Finance Act 2015 introduced disguised investment management fees which suggested that the reward of an individual which is referable to a fixed fee should be subject to income tax but that which is dependent on performance of the portfolio would be subject to capital gains tax and outside the scope of the charge.

The budget press release however indicates a drive to minimize the capital gains treatment of these rewards by 1.tightening of the rules on the computation of gains arising on the disposal of a carried interest and 2. proposing in a consultation document (on the taxation of performance linked rewards methods for determining whether the assets which drive the performance bonus are held as investments) two methods for determining whether those assets are held as investment which involve long periods for which assets must be held or averaging the periods of ownership which likely to be unworkable in the case of large funds.

Yesterday's Budget clearly indicates the Government's intention to continue to aggressively pursue those that they consider to have in some way evaded or avoided paying what HMRC maintains is the "right amount" of tax. The increased responsibilities being placed upon financial intermediaries to inform their UK resident customers with overseas accounts of their obligations to disclose under the Common Reporting Standard, the further expansion of the DOTAS regime, including the increase in penalties for those who do not comply and the implementation of further legislation to target those the government consider to be "serial avoiders" of tax are all evidence that the increased atmosphere of hostility to what was previously considered to be legitimate tax structuring is not going to drop down the Government's agenda.

The government’s stated goal is to recover £5 billion from tax avoidance / evasion. A large proportion of this will presumably come from accelerated payments on disputed tax liabilities and large interest payments on now very old liabilities. Whether the Government’s and HMRC’s approach to these historic liabilities is fair is debatable as the end target is often an individual who thought (rightly or wrongly) that they were entering into a legitimate structure and are now in a very different financial position to the one they were in when they entered the schemes. More tax driven insolvencies are likely to be on the agenda.

It is evident that Mr Osborne has been practising his conjuring skills. Look how he dazzles us with cuts to corporation tax with one hand, while snaffling our dividend tax credits with the other! Hey presto - a national living wage (but don’t look at the cuts in benefits). No rise in the rates of VAT, income tax or NICs, but an increase in IPT of over 50%, and an end to non-dom treatment for long-term residents. The changes to dividend taxation will have huge ramifications, especially for owners of SMEs. Perhaps most important will be the changes affecting non-doms - the UK has suddenly become much less friendly an environment for them.

This is a truly radical Budget. It changes the ground rules for UK businesses, their owners and their investors in several important respects:

If we add to all of that further reductions in corporation tax rates; a premium corporation tax rate for banks coupled with a reduction in the bank levy that was increased in the March Budget and changes to the profile of tax payments for larger companies, it is certainly not getting any simpler.

These are radical changes, many of which are to be made with little or no consultation. We are promised a Business Tax Road Map by April 2016. What’s left to go in it?

It may be no surprise to some that the government continues to focus on the investment funds industry. While I find it curious to describe the application of Statement of Practice D12 precisely according to its terms a "loophole", arguably the announcement on preventing base cost shift for carried interest holders is a good thing. It, coupled with some comment in the consultation document on performance linked rewards, does seem to provide comfort that the treatment of true carried interest within the capital gains tax regime is safe for now, and it does not seem entirely unreasonable to subject carry holders to CGT on their true capital gain. The draft legislation does have an unsatisfactory result, in that it does not seem to override the base cost shift entirely as it applies to carried interest, so the non-carry holders will still suffer a reduction in their base cost; in all likelihood most investors in private investment funds will not be subject to UK tax so this may have limited impact in practice. Has the time now come to legislate for the tax treatment of partnerships and their partners more generally? Another item of note for the asset management industry is the consultation document on the taxation of performance linked rewards paid to asset managers. It will be interesting to see what is ultimately proposed for categorising asset management returns between income and capital and how the government can come up with a definition of trading versus investment for this purpose only (but expressly not for general purposes – why not, I ask myself). If an approach similar to that used for the disguised management fees legislation is adopted, namely attempting to define relatively narrowly what is "safe", there may be a risk of perhaps unintended adverse tax consequences for innovative or unusual funds that fall outside a narrow safe harbour.

Some changes to the bank levy were expected, but the way it is to be changed is a surprise. The phased reduction coupled with the new supplemental corporation tax rate of 8% means a rise in tax in the medium term for banks. This may bear adversely on UK-headquartered banks because the supplemental rate is likely to be creditable for banks headquartered abroad in countries (such as the US) that operate a credit system for foreign tax relief.

Change to pensions tax relief is once more on the agenda, with the Chancellor's launch of a wide-ranging consultation ending on 30 September 2015. The Green Paper puts the case for a fundamental change to the current system of exempt-exempt-taxed pension savings to a taxed-exempt-exempt (TEE) regime. While a TEE system would flatter Treasury finances for some years to come, there would be no guarantee that future governments would not legislate to tax pension withdrawals as well.

Salary sacrifice escaped reform - for now. The Government recognises that such schemes are becoming increasingly popular and the cost to the taxpayer is rising. It therefore proposes actively to monitor both their growth and their effect on tax receipts.

Current tax reliefs were reduced as expected from April 2016: the lifetime allowance will fall to £1 million and a lower annual allowance (AA) was introduced for high earners. Incomes over £150,000 will be subject to an AA tapering to a minimum of £10,000. Those high earners who can afford to would be well advised to save as much as they can into their pension this year and to use any carry forward relief available before the AA reduction applies. For the £150,000 threshold, income taken into account is "adjusted income" which includes taxable earnings and all pension contributions, but not charitable contributions, meaning high earners cannot avoid the reduced AA via salary sacrifice.

The plans for a secondary annuity market have been sensibly delayed until 2017. The extended timetable should mean that there is time to build in a robust package of consumer protections.

For some years, successive governments have looked at the taxation of carried interest and made changes around the edges, often with anti-avoidance in mind (the mixed partnership rules, disguised investment management fees, and so on). However, this Budget marks a step change as regards the taxation of carried interest. Base cost shift is gone, as of 8 July 2015. The government is also consulting on how "performance linked rewards paid to asset managers" can be differentiated from traditional PE/VC style carried interest, with the intention that the former should be taxed as income from April 2016. However, a positive slant is that the government seems committed to the principle that carried interest should be taxed as capital gain (and at capital gains rates), albeit that the amount chargeable is now likely to be higher.

The Chancellor's reaction to possible institutional flight from the UK in the move from the banking levy to a surcharge on UK taxable banking profits recognised the mobility of capital in London, outwards as well as inwards. The changes for non-doms will be scrutinised from a similar perspective. In the weeks up to this year's General Election we heard much about the tax revenue which could be derived from non-doms and of course that the UK is such a wonderful place to be that they would never leave. Such comments failed to recognise that for true non-doms London or not London is judged on the balance of convenience. The proposals for non-doms represent a measured response. Deemed UK domicile in the 16th tax year after 15 prior years of UK tax residence, applicable for income, gains and inheritance tax, seems reasonable. The devil will be in the detail. It would be nice if the Government took the opportunity of a more coherent non-dom regime to make the rules on constructive remittance more sensible, but that is probably a vain hope. The Chancellor did borrow one idea from Ed Balls. Those non-doms earning carried interest in London will not be impressed by the new rule that carried interest attributable to UK work will no longer qualify for the remittance basis. The attack on the base cost shift arguably makes some sense but preserving capital gains treatment for carried interest yet applying a deemed UK source is much more about grabbing revenue than a coherent tax regime.

There was no shortage of fairly major announcements. For mainstream corporates, the planned corporation tax reduction to an eventual 18% (albeit over a lengthy 5 year period) will be headline news and, more generally, will help in attempts to make the UK an attractive place to do business. It will be interesting to see what, if any, impact this has on non-resident property investment structures, given that UK resident companies will pay less tax on rental receipts than non-resident companies who pay 20% income tax.

Also in the property sphere, the restriction on deductibility of interest payments will come as a shock. As a major change to the tax treatment of non-corporate residential landlords, it is disappointing that this apparently arbitrary change has been made with no prior consultation. Running residential property investments through a company seems a fairly obvious fix, subject to ATED issues, though realistically this will probably only work for landlords with numerous investment properties. The economic effects remain to be seen. A depressive effect on residential property prices is one potential effect. Another is a reduction in rental properties on the market and, consequently, rent inflation as residential landlords look to alternative investments.

The renewable energy sector will be unhappy. Following close on the heels of the announced removal of RO subsidies, the Treasury is now doing away with the Climate Change Levy exemption for energy produced from renewable sources.

There was much speculation in the press in the run up to the Summer Budget on possible changes to the taxation of non-domiciled individuals, but the extent of the changes announced still came as a surprise to many. The Chancellor's proposal to extend the deemed domicile concept to income and capital gains tax represents a significant departure from a well-established tax system in the UK - as the Chancellor noted in his speech, non-domicile tax status has been in place since 1914. As ever, the detail will be the subject of consultation, but it seems likely that in the next year or two we shall have a very different tax regime for such individuals and their offshore structures. There will be much to do to prepare non-domiciled clients for these changes.

Other significant developments include the increased inheritance tax allowance to be applied to an individual's main residence and the reduction in tax relief on pension contributions for high earners (whereby the annual allowance will reduce on a tapered basis to a minimum of £10,000). It will be interesting to see where the wider consultation on pensions tax relief will lead us - the Chancellor's statement that he is "open to further radical change" suggests that the changes are unlikely to be minor.

Although "open for business" rhetoric is now familiar, few had seriously anticipated cuts to the main rate of corporation tax, down to 18% by April 2020. A boost to the UK's tax rate competitiveness? Doubtless, along with the "triple lock", and arguably even though effective rates on dividends, and IPT, are set to increase. One side-effect will be to increase the inherent rate incentive for multinationals not to find themselves subjected to diverted profits tax.

Less familiar-sounding were gradual decreases in bank levy rates and plans to restrict the bank levy to UK balance sheets by 2021. A welcome change of direction, albeit likely neither radical enough nor implemented soon enough for some: why not abolish the bank levy altogether? The 8% surcharge on banking sector profits will be less welcome but perhaps the lesser evil.

Significant short-term cashflows for the Government are expected from tightening payment deadlines for larger corporation tax payers. Measures will be introduced with immediate effect to address "imbalances" and planning, notably limiting amortisation of purchased goodwill and utilisation of losses and surplus expenses against CFC charges.

Multinationals will note proposals for a "business tax roadmap" (April 2016) and a consultation on company distributions (autumn 2015).

This was a big budget but without much in it relating to employee incentives. It remains unclear how the Government is going to generate a further £5 billion of tax revenue through tackling anti-avoidance. Against that backdrop it was some relief there were no proposals to scale back shares for rights, the proposals to restrict carried interests were limited to investment managers and salary sacrifice is merely to be "monitored".

There were certainly a few surprises on the corporation tax side in this Budget. Aside from the headline grabbing reduction in the corporation tax rate down to 18% by 2020, those are unlikely to be overly welcome. It is hard to see any real justification for removing the ability to set losses and reliefs against CFC apportionments if you could have used those losses and reliefs to shelter the CFC's profits had they been onshore in the first place. The reforms to bank levy, coupled with the introduction of the bank corporation tax surcharge, look set to make an already uneven playing field between different banking groups and which can distort competition depending on the particular mix of UK and overseas business a group has and whether or not it has a UK parent company even more lumpy. The inference from the changes is that the UK wants bank holding companies but not banking business which is rather at odds with the Chancellor's words.

Summer Budget news for entrepreneurs and OMBs was perhaps a little mixed.

On the one hand the confirmation that the government will remove the requirement that 70% of SEIS money must be spent before EIS or VCT funding can be raised increases the flexibility of the scheme and will be welcomed by many. The appetite for start-ups looking to benefit from SEIS has been steadily increasing, and we expect this to continue. The announcement that the government will consider making crowdfunding eligible for ISAs will also be well-received.

However, this has been rather tempered by the announcement that the lifetime cap for money raised under VCTs and EIS will be reduced to £12 million (£15 million was mooted in the March budget) to comply with EU state aid requirements (so it is all the EU's fault then). There are also new rules that look to prevent money raised through EIS and VCT being used to fund acquisitions of new business, together with a requirement that, in general, businesses are not eligible for venture capital reliefs for the first time if they made their first commercial sale more than seven years ago (this has come as a bit of a shock to some of our clients - and a longer twelve year period was mooted in the March budget). There are extended lifetime caps and time limits for "knowledge-intensive companies". We are also not sure what the new condition that the money raised must be used to "grow and develop the business" adds to the current condition that the money must be used for the purposes of the business.

In the context of individuals, we might have expected the first full-fat Conservative government Budget for 19 years to leave non-doms unscathed. Not so - the government has announced an end to permanent non-dom status, with individuals to lose status after 15 years of residence in the UK. This has more than a whiff of a political gesture than a coherent fiscal policy. A number of commentators have been quick to point out that the UK coffers are likely to lose out in the longer term, with non-doms simply leaving the UK after 15 years.

It would be remiss not also to comment on Mr Osborne’s increasing resemblance to Mr Bean.

Income tax changes for residential letting: The restriction on the amount of interest which can be deducted for tax purposes is only relevant for individuals owning buy to let properties. It does not apply to commercial property. It is also not relevant for companies, including offshore landlords who own their property through non-UK resident companies: these will always be liable to income tax on rental profits at the basic rate anyway. We await the detail of the proposed replacement to the Wear and Tear Allowance; clearly it is hoped that any changes do not place a significant compliance burden on residential landlords.

Restrictions on CGT treatment of carried interest: Investment managers may be feeling a little bruised by all this as it comes hot on the heels of the "disguised fee" rules that came into force on 6 April 2015. Under these rules, sums received by investment managers for their services would be charged to income tax as part of their trading income. Arrangements (general partner share streaming or diversion and fee waivers) had been devised to structure what would otherwise be management fees as an investment return. The latest changes and the announcement in the Budget of further consultation (on performance rewards to investment managers) prove that HMRC are keeping to their promise of actively reviewing the situation

After 5 years as a coalition Chancellor, on corporate tax George Osborne had more tricks up his sleeve than Merlin in a duffle coat. Recalibrating the bank levy may eventually address the sabre-rattling from HSBC and Standard Chartered; but that will only take full effect 5 years after the offsetting bank surcharge. The further corporation tax rate reductions are welcome, and were just as unexpected as the last vestige of the dividend imputation system being dismantled. Companies will strongly consider accelerating dividends before the rates change next April, and may have to plan around reserves accordingly, so it's surprising that the Red Book figures do not anticipate any 2015/6 revenue from this at all. Less welcome, and harder to justify in terms of a coherent tax code, are the removal of purchased goodwill from the intangible fixed assets regime, and the restriction on sheltering CFC profits with losses that would be allowable had the same profits arisen to a UK company. It is to be hoped that the promised review of corporate distributions is not as ominous as it sounds.

The budget will be a bitter pill to swallow for a considerable segment of London's financial services and investment management community, and the non-dom community generally. The surprise increase in the dividend tax rates and the abolition of the non-dom tax regime in 2017 for long-term UK residents, together with the death of the base cost shift for carried interest arrangements, will lead to very substantial tax increases for many UK and foreign domiciled individuals, particularly in the private equity space and for long-term resident non-doms. Tempering with the non-dom tax regime has been on the cards for a while, given the populist appeal - but it is still surprising that it was the Conservatives who delivered what may ultimately turn out to be the fatal blow. It is too early to tell how big the fall-out will be - but for a Government that promised no increase in income tax rates, yesterday's Budget was some astute tax planning.

Although an immediate political success, with suggestions of movement towards a low-tax high-wage economy, taxpayers should not be hoodwinked into thinking this was a "give-away" budget. Most "gives" are matched or over-matched by "takes", and the forecasts show that the government expects its total tax revenues to increase substantially over the next five years.

In particular, while the UK has the ambition to remain an attractive location for the investment management industry, some investment fund managers will be waking up with something of a tax headache.

The abolition of the so-called "base cost shift" will increase the tax rate paid by private equity executives on their carried interest to 28 per cent with immediate effect. Separately, there is a consultation on new rules intended to make sure that performance fees paid to managers of more active funds - such as hedge funds, for example - are not taxed as capital gains from April 2016 but rather are subject to income tax rates of up to 45 per cent instead. And changes to the rules on taxation of individuals who are not domiciled in the UK - fund managers from elsewhere in the EU, say, with direct co-investment interests in the non-UK assets held by the funds they manage - may encourage some long-stayers to leave the UK before the new "deemed domicile" rule comes into effect in April 2017.

It is hard to argue with action being taken to deal with beneficial tax treatments created in large part by accidents of history, but the economy of the UK as a whole will suffer if successful fund managers are driven away.

The nascent Nuttall Review share buy-back regime received a setback in the Summer Budget 2015, with the news that the dividend tax credit regime would be replaced from April 2016. Changes to the Companies Act 2006 (from 30 April 2013 and amended on 6 April 2015) deregulated share buy-backs, especially when pursuant to employees' share schemes, and permitted treasury shares in private companies. The idea was to open up an alternative form of internal market to support private company employee share plans, one that did not require an employee trust to warehouse shares. Although HM Revenue & Customs published helpful guidance in 2013, unfortunately no accompanying changes were made to tax law or published practice to ameliorate the usual income tax treatment of share buy-back proceeds. But at least purchases from basic rate tax paying employees benefited from the dividend tax credit, such that no income tax was payable. This Summer Budget 2015 change adds a 7.5% tax charge when buying back shares that are subject to income tax treatment, subject to the new tax-free dividend allowance of £5,000 a year. From April 2016 the Government will set the dividend tax rates at 7.5% for basic rate taxpayers, 32.5% for higher rate taxpayers (instead of 25% of the net dividend) and 38.1% for additional rate taxpayers (instead of 30.6% of the net dividend). In contrast, capital gains tax generally applies when an employee trust buys shares from employees, and income tax is not charged in some circumstances on the buy-back of employee shareholder shares. The Government will consult in Autumn 2015 on the rules for company distributions. There is therefore a timely opportunity to lobby for changes to remove this new tax cost, or perhaps secure a usually more favourable capital gains tax treatment instead?

The phased reduction in the UK corporation tax rate to 18% from 1 April 2020 could prove to be a very shrewd and well timed measure, as we head into the closing straight of the OECD's BEPS initiative towards the end of this year. Multinationals are looking to better align their global supply chains with operational substance, and the UK is looking increasingly competitive as compared to its peers. At the same time, the measure widens the gulf with the penal rate of the diverted profits tax at 25%. The measure is projected to have an annual cost of £2.5bn by 2020-21, which takes account of the anticipated positive behavioural response from multinationals. This may prove to be unduly pessimistic, as we have seen that the prior tax rate reductions under the Coalition Government have encouraged significant inbound investment into the UK, although the benefits tend to be back-loaded and take time to feed through in terms of additional tax receipts.

The Chancellor also announced three important measures to shore-up the UK corporation tax base, which will have a bearing on inbound investment and supply chain structuring. The first concerns the broad ranging denial of amortisation relief going forward on the acquisition of goodwill and customer related intangibles, subject to grandfathering rules for past acquisitions. The Chancellor unashamedly justified this measure as an attempt to broaden the corporation tax base, but he does so at the cost of placing the UK at a disadvantage to other key jurisdictions competing for inbound investment. The measure closes the door on a contentious area of the intangibles code. The second is a defensive, targeted anti-avoidance measure which seeks to close down a perceived loop-hole in the intangibles rules which facilitated the transfer of IP from the UK without triggering a UK exit tax at market value. The third is the repeal of rules allowing multinationals to set-off their current year UK tax losses against a CFC charge, a restriction which seems difficult to justify as anything other than a penal measure, given the very existence of such losses would tend to indicate there is no incentive to artificially divert profits from the UK for tax reasons alone, and may also potentially raise issues from an EU perspective.

The Summer Budget saw significant changes to the tax position of non-domiciled individuals.

It was a Labour pledge and a measure that Ed Miliband would have been delighted to implement, but it is the new Conservative Government that has committed to legislate so that non-UK domiciled individuals who are long-term residents of the UK will not be able to claim non-domicile status for an indefinite period of time.

From 6 April 2017 (following a period of consultation), anyone who is resident in the UK for more than 15 of the preceding 20 tax years will be deemed UK domiciled for UK tax purposes. Such individuals will not be able to claim the remittance basis of taxation, which does not tax foreign income and gains so long as they are not remitted to the UK, and instead will be taxed on the arising basis on their worldwide income and gains.

Moreover, anyone who had a UK domicile at birth will be deemed UK domiciled for UK tax purposes whenever they are resident in the UK, irrespective of whether they have acquired a foreign domicile under general law.

Significant changes have also been introduced to the IHT treatment of non-doms. Non-UK domiciled individuals who are deemed UK domiciled under the new rules will be subject to UK IHT on their worldwide assets. They will also continue to be so for five tax years after they cease to be UK resident. And all UK residential property held by non-UK domiciled individuals will be brought within the charge to UK IHT from 6 April 2017 (following a period of consultation). Targeted in particular is UK residential property held indirectly through offshore companies or other vehicles or within excluded property trusts (where the trust holds the UK residential property through an offshore vehicle).

You certainly couldn't accuse George Osborne of ignoring the fund management industry recently. In three fell swoops he has dismantled the fund manager tax regime that has been in place since 1987. First we had March's disguised investment management fee rules, albeit these are in the context of what might generally be considered structured schemes. Now yesterday he announced the immediate end to the application of "base cost shift" to carried interest returns. This came out of the blue with no forewarning or chance of consultation, which is particularly surprising given the discussions around the disguised investment management fee rules earlier this year and HMRC's stated desire for engagement with taxpayers and with industry experts. Thirdly, HMRC have announced a consultation to determine whether investment funds are investing or trading simply to determine whether carried interest returns should be taxed as income or capital. As with the disguised fee process, while stating that these new rules are intended to be targeted HMRC have proposed the unfortunate approach of saying everything is income unless the fund activities fall within a prescribed scope of investment activities. It is only to be hoped that this "if it's not out it's in" method of drafting is not going to become HMRC's preferred approach to tax legislation to allow them to avoid the hard task of defining exactly what it is that they are concerned about and, rather, leave it up to the taxpayers to persuade them what should not be affected by whatever new rules are put in place.

"We have to move Britain from a low wage, high tax, high welfare society to a higher wage, lower tax, lower welfare economy". Stirring stuff…although I had to re-check the "lower tax" bit once I'd read all of the announcements. Like all Osborne Budgets, it pays to let the dust settle. An apparent gift with one hand is often removed with the other. For businesses, the further reduction in corporation tax to 19% in 2017 and 18% in 2020 is appealing. Britain's headline rate is right down there with Switzerland, Hong Kong and Ireland. However, that tax will now have to be paid earlier and, for some UK-based businesses, the tax cut will be absorbed by the cost of implementing the living wage. Also to weigh against the CT cut, especially for entrepreneurs, is the dividend tax hike - so much for the gimmick of the new income tax lock! Grossing-up under the tax credit system will go and markedly higher tax rates of up to 38.1% will apply to the extent dividend income exceeds £5,000. It may encourage more to retire by selling their companies rather than holding for dividend income. There will be implications for buy-backs and other arrangements. There will be consultation on dividend tax reform in the autumn. Finally, try as I could, I couldn't spot the repeal of the DPT regime (although the decrease in the CT rate makes it more punitive still). So, "lower tax"? Well, yes and no.

With the main rate of corporation tax due to fall to 18%, the UK looks increasingly attractive as a European holding company jurisdiction, but only once the uncertainty regarding the European referendum is out of the way.

Many of us expected this to be a relatively quiet budget for tax, thinking that the main focus would be on welfare announcements. However, there were quite a few surprises - and most of them unpleasant. The immediate removal of relief for acquisitions of goodwill seems rather unnecessary. Why is the government suddenly so concerned about tax differences between acquisitions of assets and shares? Removal of stamp duty on acquisitions of shares would have been a more pleasing way to level the playing field.

Bringing forward the time at which large companies have to pay their corporation tax sounds relatively innocuous but will have significant cash flow implications for groups and is estimated to bring forward huge revenues for the Treasury coffers.

The reform of the complicated regime of dividend tax is welcome, with its tax credits that no longer accurately reflect tax paid by anyone but were effectively a fudge to keep basic rate taxpayers out of having to complete a tax return. The announcement of a review into the tax treatment of pension contributions is interesting - but this looks like a missed opportunity to announce another fundamental reform - the bringing together of income tax and national insurance. Although, we are told that OTS will be asked to "review the closer alignment" of these taxes.

Some big reforms here, and maybe some big unintended consequences as well. In abolishing amortisation relief for goodwill and customer relationships, the Chancellor has fundamentally changed the economics of asset purchases as compared to share purchases: but not, as he suggests, levelled the playing field. It is trailed (without further explanation) as an anti-avoidance measure, but rather than introduce a targeted provision, the Government has opted for the blunderbuss approach by effectively returning goodwill to capital gains treatment (only without the benefit of indexation). Amortisation relief for acquired IP was fundamental to the coherence of the intangible fixed assets regime and was introduced after much painstaking consideration and consultation. When the Government decides to upset this coherence, it would at least be nice if it explained why and consulted on how to do it. One immediate result is likely to be asset purchasers attributing more value to registered IP on future transactions.

The reforms to dividend taxation purport to discourage self-incorporation by narrowing the rate differential with trading and employment income, but at the same time the rate differential between dividends and capital gains is increased. Expect to see a proliferation of schemes designed to achieve returns of capital …

Corporation tax: controlled foreign companies: loss restriction: TIOPA 2010, Part 9A, Chapter 21, section 371UD permits losses, certain expenses and other items such as group relief and charitable donations to reduce the CFC charge. It is to be repealed with respect to CFC profits which arise on or after 8 July 2015. This measure will further ring-fence the CFC charge and disincentivise operations that give rise to CFC profits. Unlike the measures to prevent loss refreshing introduced as Part 14B of CTA 2010 earlier this year in FA 2015, this removal of relief for losses and related items from the CFC charge is of general application and is unconnected with any tax avoidance purpose. The measure is expected to raise a modest amount of tax but will frustrate groups with economic losses. Corporate groups normally seek to use losses and excess expenditures as soon as they can. This option will no longer be available for groups with international operations. The policy message is that if the offshore activities that gave rise to the CFC profits were undertaken in the UK, then the losses and other surplus expenditure may be used in the normal way. In conjunction with the message that corporation tax rates will continue to decline, onshoring is encouraged.

Financial institutions and tax advisers to notify their customers of CRS and FATCA: The Common Reporting Standard and FATCA style compliance represent one of the biggest shifts in international cooperation among tax administrations. Routine automatic exchange of financial information will change tax compliance beyond recognition. Finance Act 2013, s 222 authorises UK participation in this project. Section 222 is to be amended to allow HM Treasury to make regulations to impose customer notification obligations on financial institutions, tax advisers and other professionals about information relating to HMRC will receive under the various international agreements. While financial intuitions will groan under the weight of further obligations in this area, taxpayers will welcome the right to receive this information. If tax compliance progresses from cat-and-mouse to both taxpayers and administrators knowing what the other knows, a more cooperative relationship is likely. If this merely requires tax advisors to do the finger wagging on behalf of HMRC, then the opposite is more likely. The measure should cut out the middleman and require HMRC to provide the information it receives on foreign accounts to taxpayers. This would simplify tax return preparation, encourage compliance and offer a useful service to taxpayers instead of trying to set more traps.

So farewell to another aspect of the 1987 Guidelines on the use of limited partnerships as private equity investment funds. Summer Budget 2015 announced the death of base cost shift, enhanced base cost shift and cherry picking, with the Chancellor unveiling instead a measure to tax holders of carried interest on their "true, economic gain". The measure, which affects all carried interest arising on or after 8 July 2015 regardless of when the arrangements were entered into, will apply where an individual performs investment management services for a collective investment scheme through an arrangement involving one or more partnerships (lovers of the disguised investment management fee rules from Finance Act 2015 will recognise a number of these concepts, which will no doubt have the same broad application). Where this is the case, any sums received in respect of carried interest will constitute a chargeable gain and be subject to capital gains tax, regardless of the source(s) from which the carried interest is derived.

Indeed, it has been a hard few years for asset managers. The dream of the 2013 UK Investment Management Strategy may seem in tatters, for those who have had to navigate through the choppy waters of salaried members, mixed membership partnerships, disguised investment management fees and, in Summer Budget 2015, changes to the taxation of carried interest. But that is not all. Alongside the most recent salvo, HMRC has also issued a consultation on the taxation of performance linked rewards, for managers and advisers to reflect upon from their sun loungers given the closing date for comments of 30 September 2015.

The backdrop to the consultation would seem to be a reluctance on the part of HMRC to allow managers operating strategies outside the private equity and venture capital spheres to use carried interest and other arrangements to derive performance linked rewards as a return from the fund, taxed as a capital gain rather than a fee, resulting in a lower effective rate of tax. The level of detail in the proposal suggests the consultation is at the stage of "how shall we implement" rather than "shall we implement at all".

Following increasing concern amongst the banking sector about the impact of the continued increases in bank levy on the UK's competitiveness as an international banking centre (to the extent of leading certain international banks to reconsider whether the UK remains the right jurisdiction for their headquarters), the Summer Budget made a number of announcements to reform the UK's taxation of banks. UK banks were given some good news in the form of gradually phased reductions in the bank levy (and for those headquartered in the UK, eventually a restriction on its scope to their UK operations only from 2021), but this will be offset by the swifter introduction of a corporation tax surcharge of 8% from 2016. The Government appears to be attempting to reduce the risk of banks migrating out of the UK without reducing the overall tax take from banks. The changes seem likely to increase the level of taxes on UK banking operations, but reduce them for UK headquartered international banks.

It was really no surprise that the Government announced a slew of new measures to tackle tax evasion and avoidance and generally tighten compliance regimes. Little more needs to be said about direct recovery of tax debts than already has been, save that despite the safeguards to be adopted following the consultation, problems and unfair use of the powers are inevitable in practice. The measure also extends to tax credits, an area where recovery actions by the Government for overpayments have had more than their fair share of controversy. The effectiveness of the measure will of course depend on the adequacy of assets in the accounts to meet the tax debts.

There will be a new range of special measures and tools designed to encourage voluntary corporate tax compliance by large businesses. This is to be subject to consultation but the more interesting measures amongst those expected are anticipated financial penalties for business that persist in aggressive tax planning practices and additional reporting requirements that would require large businesses to publish their tax strategy, setting out their approach to tax planning. HMRC will no doubt be disappointed if taxpayers show the same level of compliance with the mooted Code of Practice, which will define the standards HMRC expects large businesses to meet, as HMRC has with the Taxpayers' Charter.

Investment in additional HMRC staff to tackle non-compliance by large businesses are to be welcomed and can only improve the efficiency with which HMRC enquiries and disputes are conducted.

For wealthy individuals, there will be legislation to require financial institutions and other advisers to notify their clients that the information is being exchanged under the Common Reporting Standard. The UK will start to receive and share information regarding offshore accounts in 2017. The existing contractual disclosure facilities will be brought to an end and replaced with a new tougher disclosure facility in 2016. HMRC will take a tougher stance on enforcing penalties for offshore tax evasion and there will be new civil penalties and a new criminal offence for failing to declare offshore income and gains. For those who need to regularise their affairs, it is time to come clean in 2015.

"There had been speculation that the Chancellor would take aim at the buy-to-let market, which apparently accounts for 15% of all new mortgages, so restricting to the basic rate of tax relief for finance costs on residential property (typically mortgage interest) was not a surprise. However, for the time being at least, the relief has not been abolished, and the impact of the change is being softened by the phasing-in of the restriction over 4 years from the 2017-2018 tax year. This is a shrewd political move, meaning that the restriction will not come fully into effect until just before the end of the Government's term of office, allowing time to assess the impact and decide whether the measure has achieved the desired effect in terms of the housing market. It will then be for the next Government to decide whether further action (such as removal of the relief altogether) is needed.

Although there was nothing specific on employee share plans in the Budget, that in itself does not matter as there is still plenty to do working out and digesting changes in 2013 and 2014. Two related Budget announcements stand out, however. The first is the change to dividend taxation for individuals from 2016. Aside from companies needing to change their employee communications in due course for SIPs and possibly other share plans, the prospect of all employees being able to receive up to £5,000 of dividends each year opens up some very interesting opportunities. Some employers may well start trying to think of ways to use this in the way that profit-related pay tried to maximise use of this allowance, to make it a tax-free way of paying remuneration. It also offers opportunities for companies buying back employee shares or waiving partly-paid share obligations. The second notable change is the immediate removal of the base cost shift for manager partners in private equity funds. This allowed them to be transferred the high base cost in portfolio companies of the investor partners, who had little need for it, and thereby reduce manger capital gains with a financial result that could be far more valuable than the effective rate of tax on any gain. Further consultations on this area are announced, which have already been taking place anyway on geared growth on employee shares, making this an endless area of review, though to date with little action. For those with wider practices, consultations on termination payments, IR35, and further monitoring of salary sacrifice arrangements may eventually produce some change, and the pension proposals are very exciting.

The focus of the consultation document on performance linked rewards paid to asset managers is, naturally, the impact for the asset managers themselves. But the discussion around the impact on investors, and the general law on "trading" vs. "investment", is noteworthy too. Non-resident funds are generally only exposed to direct UK taxation if they are trading in the UK. The threshold for trading activity is very difficult to pin down, and the condoc recognises this - in particular in relation to "modern financial markets" and "the complex strategies and instruments used by asset managers". What is especially interesting is the suggestion in the condoc of an HMRC reluctance to challenge funds taking the position that they are not trading. This seems based on the complexity of the analysis and the resources required rather than an assumption that an exemption from UK taxation (like the Investment Manager Exemption) would generally be available.

Another interesting item is the announcement of a consultation later this year on the rules for company distributions. No further details are given, but it has the potential to be significant if it relates either to the treatment of distributions by the company making them (now in Part 23 CTA 2010) or the exemption regime for corporate recipients.

The Summer Budget contained much anticipated changes to the bank levy and a new and unexpected 8% surcharge on banking profits. These are significant reforms intended to strike a balance between ensuring the competitiveness of UK based banks and raising revenue.

The impact of the changes will vary across different banking groups. Although all groups will benefit from the gradual reduction in the levy rate, this will be offset and may be eradicated at least in the short term by the effect of the surcharge. Losers will include smaller banks and building societies excluded from the bank levy, but not excluded from the surcharge by the relatively small annual allowance of £25m

UK based groups will benefit, eventually, when the scope of the levy is limited to UK balance sheet liabilities. Changes in recent years to the territorial scope of corporation tax – such as the foreign branch exemption - should also help as the surcharge could in effect be primarily on UK rather than worldwide profits.

Government figures show an expected increase in net revenues over the next few years as a result of these changes and there will be much debate over whether the changes are beneficial or not and whether they are enough to encourage UK based groups to remain UK based.

On the plus side there is more certainty - constant changes to the levy were destabilising and its rationale increasingly questionable as it moved from a tool for encouraging behavioural change to a revenue raising measure. There is also merit in taxing by reference to profit rather than by reference to balance sheet liabilities.

Other significant announcements include confirmation that help will be given in situations where the bank levy represents double taxation because contributions are also made to the Eurozone Resolution Fund. This has been considerable uncertainty on this point.

Otherwise, the Chancellor announced a number of potential reforms at very high level yesterday, and there will be a busy period ahead. One such announcement was a consultation on the taxation of company distributions for corporation taxpayers. This is an issue of fundamental importance in the UK tax system and there is naturally much anticipation of what may come.

Given the focus on individuals in the July Budget - especially middle class individuals - anyone would have thought this was a pre-election Budget not a post-election one. The attack on non-domicile status for long term residents and UK born individuals is a real crowd pleaser, and the abolition of our ridiculous deemed credit system for dividends can only be welcome to any junior lawyer who's ever had to try to explain it to a client. Less popular will be the further reduction in the lifetime allowance for pensions and the annual allowance for top earners, which may lead more frivolous readers to abandon their pension altogether to "live fast and die young". Anyone in private equity who didn't realise their gains before 8.7.15 will be frantically considering the effect of the new restrictions on the taxation of carried interest, and hoping it doesn't apply to them. For corporates, much less this time around - the reduction in rate to 18% by 2020 will be welcome, the bringing forward of payment dates rather less so. My personal pick for "most unwelcome change" is the new bank surcharge of 8% from January 2016 - and the fact that it will apply before the use of carried-forward losses.

The Summer Budget seems to contain an awful lot of tinkering across a wide range of taxes, not all of which is necessarily for the better (for example, the way in which banks have been treated).

For me, the most significant announcement on business taxes generally (apart from further reductions in the headline rate of corporation tax) was the promise of a consultation on the rules for company distributions, but I'm left wondering precisely what the Government has in mind.

It is notable that HMT struggles to come up with a justification for the tax lock. The policy objective is said to be "to legislate that the rates of income tax, NICs, and VAT may not increase", which is not even accurate as a description, given that the legislation will not in fact prevent such an increase.

And one of the major surprises of the Budget provides an immediate exception to the principle: there is to be an immediate rise in the rate of income tax as applied to dividends. Judged on its own merits, though, the change can be seen as reversing an historical anomaly: for a provider of, say, professional services, it is only very recently that the combined cost of corporation tax and dividend taxation has actually been lower than the income tax and 2% national insurance surcharge that would be payable on the same income if received directly.

The complete elimination of the UK's imputation system will also end a taxpayer-friendly anomaly in an entirely different area. There are still quite a few tax treaties which effectively prevent the UK imposing withholding tax on dividends paid by REITs so long as (non-REIT) dividends carry tax credits. HMRC will certainly be pleased.

Although companies will welcome the headline reduction in the corporation tax rate, the restriction on corporation tax relief on goodwill amortisation is one of several more subtle (effective) tax increases.

Unlike the recent change to deny entrepreneurs' relief on goodwill, which was targeted at transfers between related parties, this appears to be a blanket measure. In our increasingly dematerialised world a company's value rarely lies in its tangible assets, with much value typically being attributed to goodwill. So a restriction on amortising purchased goodwill is a blow to anyone intending to buy a business and may steer more buyers towards share purchases.

There were two changes announced in the Budget which potentially affect investment into residential property.

First, the proposal to bring residential property held through an offshore company into the inheritance tax net for non-domiciled individuals will re-open a debate about whether it is better for such individuals to own property directly or through an offshore company. The change is consistent with the Government's drive to discourage so-called "enveloping" of residential property, which has included charging higher rates of SDLT to corporate purchasers of residential property for non-business purposes and the introduction of the Annual Tax on Enveloped Dwellings.

Experience to date has suggested that a significant number of private clients have preferred to continue holding UK residential property through offshore companies. The abolition of the IHT benefit however, removes a major driver behind that decision and potentially could trigger a further wave of "de-enveloping" (ie extracting the residential property out of the company) over the next 18 months or so.

Second, there will be concern that the future loss of higher rate tax relief on mortgage payments could dampen enthusiasm for investment in the Private Rented Sector. However, "buy-to-let" investors could instead find that it is more attractive putting their money into tax-exempt property funds which invest in PRS. The changes to tax relief for individual property investors could have the effect of actually increasing the attractiveness of establishing such funds (REITs or PAIFs) to invest in PRS.

The amendments announced to the venture capital schemes are generally more restrictive than those proposed earlier in the year, which suggests that the Government has had feedback from the EU on its original proposals (and presumably therefore is fairly confident that the new proposals will receive State Aid approval). New rules which prevent VCTs (whenever the money was raised and whether or not the investment is intended to be a qualifying holding) using their money to acquire shares, and a ban on both EIS and VCT money being used to acquire trades or assets have also been announced. Although we must wait until the detail is published next week in the Finance Bill, on the face of it this represents a new very significant restriction to the venture capital regimes. If it is as significant as it appears, then it is unfortunate and unhelpful that such a restriction was not part of the March consultation, and it would be interesting to understand the reasoning for this - was this a measure introduced at the last minute after responses to the March consultation highlighted the use of VCT and EIS funds in this way?

The government may not be looking for a silver bullet with its pensions tax relief consultation: in fact, given the recent record on pension reforms that would be a very long shot.

Some realism about the task here may explain why the Green Paper is at pains to point out that the most effective result may be little or no change. Does that prejudge the outcome? Not necessarily. It is certainly conceivable that a radical re-engineering of pensions could leave them looking like just another form of long-term savings – much more simple to explain and much less constrained by special tax rules.

The fact that the Chancellor makes explicit reference to ISAs in this context is perhaps significant. It may also be significant that long-grassing the tax relief to the point of retirement in the manner he describes would give the Treasury a significant immediate boost because of the withdrawal of upfront tax relief on contributions. Good news for bringing down the current deficit, although possibly not such good news for future generations who could well be called upon to support the favourable tax treatment accorded to an ageing population at the point of retirement.

The reduction in tax relief on pension contributions for high earners was expected but is not necessarily welcome - it adds another layer of complexity onto what is already an increasingly difficult to navigate pensions taxation system. If there is a radical overhaul of pensions tax arising from the Green Paper, it is to be hoped it really does follow the often touted but generally ignored "simplicity" principle.

While salary sacrifice on pensions tax contributions has not yet been withdrawn by the Chancellor, the Budget document notes rather ominously that salary sacrifice arrangements are becoming increasingly popular and that the cost to the taxpayer is rising. The government is therefore going to monitor actively the growth of these arrangements and their effect on tax receipts, and we may expect to hear more on this area in the future. Thousands of businesses and millions of employees would find themselves out of pocket if salary sacrifice were abolished, and many would see this as another raid on pensions.

And to think in advance we thought that all we would have to talk about was the soul-sappingly idiotic "triple tax lock"… as to which, what are we to make of a chancellor who legislates to chain his own hands because he can't trust himself?

George Osborne continues the ignoble tradition of hiding a few nasty surprises away from the speech, and in this case one of the bigger ones is the denial of relief on goodwill purchased by corporates. This is just a revenue grab - although expressed as a levelling of the playing field between share and asset acquisitions that justification is somewhat spurious given the huge differences in tax treatment that remain. It also drives a coach and horses through the conceptual integrity of the intangibles legislation. On the upside though it should make it easier to agree that deals should be structured as share sales.

Elsewhere, the increases in effective dividend tax rates were arguably overdue: the discount to the main rates of income tax applicable to dividends had not been adjusted since corporation tax was much higher than now and so overcompensated for the second level of taxation on the profits at corporate level.

Against this, prior to the changes, we had reached a point where the tax payable on a given profit by an unincorporated trader was almost exactly the same as the total paid by an incorporated trader on the same profit and its shareholders on the resulting dividend. This greater neutrality - now lost - was perhaps to be welcomed. The changes also reintroduce a significant differential between the top rate of dividend income tax and non-entrepreneurs' relief qualifying CGT, which will inevitably put stress on the s.701 clearance procedure process in private company deals and increase the desire for planning on public company returns of capital.

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