The Government is continuing to focus on anti-avoidance measures to boost its tax receipts. In this vein, the Government intends to use the provisions on Disguised Remuneration introduced in 2011 against those who have not yet paid "their fair share of tax" and is considering how to deal with the increased use of salary sacrifice arrangements.

No doubt, buoyed by the recent decision in their favour in the Rangers case, it is likely HMRC will now pursue those who did not use the Employee Benefit Trust Settlement Opportunity which closed at the end of March and who are still the subject of open enquiries. The Government's statement that it will consider future legislation to close down any new schemes which avoid tax on earned income underscores the Government's intention to tax earned income as such. Where necessary, any new legislation will take effect from 25 November 2015.

Companies should be aware that the continued use of salary sacrifice in its current form may have a limited shelf-life, depending on the outcome of the Government's further deliberations.

It is trite to say that nobody condones tax evasion. Nevertheless, without condoning evasion it is possible to take the view that not every anti-evasion measure can be justified or applauded. Some of those announced in the Statement - particularly the proposed new corporate criminal offence - sound as if they may be going too far. Provisions which are supposed to stop the sharks usually don't.

In the private wealth sector, there will be significant relief at what was not announced in the Autumn Statement. Fears about changes to entrepreneurs' relief and Business/Agricultural Property Relief proved largely unfounded (aside from one technical improvement promised for ER). The decision not to abolish deeds of variation is welcome and one suspects that the promise of ongoing monitoring probably indicates an intention to kick this one into the long-grass rather than an active threat.

We obviously await much more detail on the non-dom consultation, particularly around offshore trusts. I suspect we will not get draft legislation on the latter, but we may get an indication of the direction of travel within the next few weeks. The promise of improvements to Business Investment Relief is welcome. The SDLT changes for second homes may hit high-end London properties even harder. Conversely, it makes the 15% SDLT for company purchasers look just as attractive as purchasing in individual names.

The changes to the venture capital schemes were largely as anticipated. They will reduce the number of EIS, VCT and SITR opportunities, but we suspect that other opportunities will emerge.

An arsenal of anti-avoidance provisions introduced in the past 9 years has resulted in Stamp Duty Land Tax (SDLT) becoming a cash cow for the government. This is particularly the case for SDLT charged on dwellings where the rates have become much higher than those applicable to commercial or mixed property.

Today, even higher rates of SDLT were announced on purchases of buy to let residential properties and second homes, to take effect from 1 April 2016. The higher rates will be 3% above the current SDLT rates. The government will consult on reliefs for corporates or funds making significant investments in residential property, possibly by reference to a test that they own more than 15 residential properties.

It remains to be seen whether or not the increase will apply to a company purchasing a dwelling for letting to a connected individual which is already subject to the penal 15% rate.

We will have to wait until the publication of the draft Finance Bill to better understand the scope of the proposed changes announced by George Osborne. The lack of detail in the statements from HM Treasury gives practitioners little choice.

Whilst the continuing changes to the taxation of fund manager remuneration are likely to cause significant debate going forward, it is the ongoing attempts of HMRC to influence corporate taxpayer behaviour that particularly caught my eye. Making large businesses publish a tax strategy, new offences for corporate facilitation of tax evasion, amendments to the disclosure regime, further anti-avoidance legislation and a penalty regime under the GAAR all point to HMRC being frustrated with certain taxpayer behaviour. However, you cannot help but feel that this is an overreaction to the antics of a minority of taxpayers who could be dealt with by better targeted measures (and indeed sanctions which already exist).

There was also no noteworthy announcements with respect to BEPS, save for confirmation that the OECD proposals under Action 2 (hybrids) will be implemented in time for 2017. And still no confirmation as to when revised guidance on the DPT can be expected.

Not the most exciting of Autumn Statements tax-wise. There was the usual raft of anti-avoidance measures in respect of schemes which in all likelihood are not widely used and the predictable further raid on properties, especially residential. This included the additional 3% of SDLT to be applied to current rates for the purchase of additional residential properties above £40,000, the proposal to reduce the SDLT payment window from 30 days to 14 days and the requirement from April 2019 to make a payment on account of any CGT due on the disposal of UK residential property within 30 days of the completion of the disposal.

Perhaps we'll have to wait for the more "exciting" stuff, including the announced changes to legislation affecting employment-related securities and the rules on the existing tax-advantaged share schemes and non-tax-advantaged schemes, the changes to the entrepreneurs' relief rules to soften the impact of the Finance Act 2015 changes and the introduction of legislation requiring large businesses to publish their board's detailed tax strategy, its appetite for tax planning and its relationship with HMRC.

For larger businesses, the sting in the tail could be the apprenticeship levy. Whilst set at only 0.5% of employment costs, the Treasury estimates that it could raise £2.7bn in 2017/18, which is roughly 6% of the total corporation tax bill in 2014/15.

This was the third "fiscal event" of 2015 following on the heels of the Summer Budget and we are only a few months away from Budget 2016. Accordingly, as predicted, the focus was on the spending review and economic forecasts rather than dramatic fiscal changes which can be left to the Budget.

The Chancellor described this as a big spending review from a government that does big things but it has largely bypassed medium sized businesses, the backbone of the UK economy.

One of the Chancellor's priorities is to rebalance the UK economy so we are not over-reliant on any one sector or region for growth. We've seen continued investment in infrastructure which is welcome but we feel that the Chancellor is not doing enough to help the UK mid-market. Mid-market companies - those with a revenue of between £10million and £300million - create one in four private sector jobs, deliver £1tn in revenue and are geographically spread across the country. The UK mid-market must be at the heart of the Chancellor's future plans.

As well as the continued focus on tax evasion and avoidance, the biggest losers in the Autumn Statement were property investors, including foreign investors, who will be hit by a hat-trick of measures.

A 3% increase in stamp duty on second homes and investment properties from April 2016, an acceleration of capital gains tax payments on residential properties to 30 days after sale and a housing benefit cap potentially hitting rents will make property investment a less attractive option.

The Chancellor's commitment to delivering the £12bn welfare saving in full was a surprise that meant there was no hole in his spending cuts to be filled with additional taxes. The Chancellor said that based on the OBR's growth forecasts, the increase in tax receipts along with reduced government borrowing costs should keep his plans to eliminate the deficit on track. However, it will be interesting to see how robust these forecasts prove to be as the tax receipts in recent months have been weaker than expected.

Large employers with employment costs broadly over £3m will be subject to the apprenticeship levy announced in the last Budget and the rate was announced as 0.5% of employment costs.

Given that this was always going to be another very political Autumn Statement, it was perhaps predictable that most of the corporate and other business tax announcements would be somewhat sketchy. Further detail is awaited on a broad range of topics - including the promised consultation on company distributions, an apparent broadening of the "transactions in securities" regime and some further changes to the corporate debt and derivative contracts codes; and a proper assessment of the full impact of the announcements will therefore have to wait. In contrast, the new anti-avoidance provisions charging payments received for the assumption of responsibility for tax deductible equipment lease payments and addressing the manipulation of disposal values have been made available and take effect immediately. It is not surprising that the Government are frustrated that (as they see it) it is still proving necessary to legislate to counteract schemes disclosed to them in these areas and, in that context, the sheer breadth of some of the detailed drafting is perhaps only to be expected. Viewed in conjunction with, say, the new rule targeting the use of voluntary liquidation as a technique for "converting" income distributions into capital receipts, it remains clear that HMRC will continue to bring forward specific provisions to deal with identified (or perceived) abuses rather than fall back on the GAAR (with its "double reasonableness" hurdle).

With the strapline of encouraging home ownership and development, the Chancellor has decided to put an extra 3% surcharge on the normal rate of SDLT for property purchases over £40,000 where the buyer is acquiring the property as a second home or investment. Will this penal rate of SDLT truly deter people from buying investment property and give first-time buyers a better bargaining position when entering the property market? Probably not. Instead, will this extra cost on investors be passed on to their tenants in the form of an increase in market rent? Probably. It seems that those currently renting with the dream of one day owning their own property will now be faced with a higher rent and therefore less income left to save towards their deposit.

The intention is clearly that the higher rate of SDLT for additional residential properties should not apply to institutional investors. It is to be hoped that HMRC will consult fully with the property industry to ensure that corporate and institutional investment is not affected and that any concerns are properly addressed in the legislation. The SDLT regime applying to residential property is now an overly complex area made more difficult by the uncertainty of when a property is to be classified as residential.

The Autumn Statement confirmed that HMRC is pressing ahead with requiring large businesses to publish a UK tax strategy but the voluntary Code of Conduct appears to have been replaced with a "framework for cooperative compliance". This change in language suggests HMRC have heeded feedback during the consultation period that HMRC's conduct is as important as that of the taxpayer in creating a low tax risk environment.

On the evasion side, it was confirmed that HMRC will legislate to introduce a Bribery Act style offence for facilitation of tax evasion but not in the FB 2016. Details will be released on 9 December. They will also consult on a creating an express statutory requirement to correct historic offshore non-compliance within a defined window, together with an enhanced penalty for failure to do so. It is presumed that this penalty will be added to any other penalty they can levy.

The Statement was light on big technical changes, but there is still plenty of detail to dig into. Further returns are being extracted from the residential property sector, and getting the corporate/fund exemption right will be important (see for example the original very narrow exemptions from 15% SDLT). A cynic might think that the natural result will be higher rent in the private buy-to-let sector as landlords seek to maintain yields.

The absence of major changes to entrepreneurs' relief, despite widespread speculation to the contrary, was welcome -especially for practitioners trying to get deals done pre-Christmas. The prospect of wrestling with a re-invigorated set of TiS rules and a new TAAR is rather less so.

The practical implications of the proposed changes to tax administration could be significant. It appears the government's vision is of a smaller HMRC workforce focussed on high-value or technical issues, with day-to-day activities largely automated. The success of that project will depend on how well the IT actually works and the ability to retain key staff at the same time as making large efficiency savings. The extra resources promised for looking into non-compliance, and the focus on the returns generated by this investment, may well result in more aggressive behaviour by the authorities.

Not a great leap forward from a business or employment tax perspective. The anticipated apprenticeship levy will be an unwelcome cost for employers (and for employees who will no doubt bear part of the cost in depressed earnings). Clearly a big revenue raiser for the Government. How long will the rate remain at 0.5%? Other measures - relating to stamp duty and options, changes to the intangibles related party rules and company distributions - are tinkering at the margins. Meanwhile the net continues to close in on employment taxation, potentially with retroactive effect, with changes announced to the disguised remuneration rules and taxation of asset managers. Salary sacrifice arrangements, which are arguably looking a little shaky in the light of recent case law, are now also under formal review.

In his speech, the Chancellor announced that the government would take "action on disguised remuneration schemes". The supporting documents published by HM Treasury make it clear that the government will consider legislating to close down any further new schemes intended to avoid tax on earned income, where necessary, with effect from 25 November 2015. It is not clear which specific arrangements are under HMRC's scrutiny, but legislation to tackle them may well be included in future Finance Bills.

We await the promised legislation which is intended to "streamline and simplify aspects of the tax rules" for both tax-advantaged and unapproved share plans. Clarity of the treatment of employment-related securities and options held by internationally mobile employees (such that the tax charge will arise under the employment-related securities options rules rather than earnings) is to be welcomed.

Salary sacrifice arrangements remain under the spotlight, with the government undertaking to obtain further evidence to inform its approach - it may be that a more substantive update can be provided at Budget 2016.

Whilst it comes as no surprise that the Chancellor is proposing a raft of new measures to tackle tax avoidance and evasion, the imposition of a penalty of 60% for avoidance schemes which fail by reason of the general anti-abuse rule (GAAR) is a little surprising. More than two years on since its formation, the GAAR panel is yet to consider any tax avoidance cases and one is left questioning whether the GAAR was necessary given the numerous anti-avoidance legislation targeted at what HMRC consider to be abusive tax arrangements.

The rules on disguised remuneration were introduced to combat the proliferation of planning using employee benefit trusts to avoid income tax and were followed by an EBT settlement opportunity. However, many employers considered the terms of the EBT settlement opportunity to be insufficiently attractive and elected to leave their EBTs in place. The Chancellor has now announced that the government intends to take action against those who have used or continue to use disguised remuneration schemes. As the form this action will take is unclear, this announcement will lead to increased uncertainty for many taxpayers.

As part of the same announcement, the Chancellor also set out the government's intention to legislate in the future to close down any new forms of tax planning that avoid tax on earned income and raised the possibility that the future legislation could be backdated to 25 November 2015.

Taxpayers who have utilised EBTs can expect further scrutiny from HMRC and increased pressure to settle their cases.

There are further clouds on the horizon for investors in residential property - as seems to be the case whenever George Osborne stands up these days - given the proposed 3% additional SDLT on second homes or buy to lets. This seems to catch even low value and otherwise exempt transactions as well as mansions, and will mean an eye watering 18% rate for corporate purchases where the company owner or beneficiary cannot substantiate the property as its principal private residence, but we shall see the detail in due course. Then there is a proposal to accelerate the payment of CGT on disposals of such property - but not any other gains - to 30 days after disposal rather than through the normal self assessment process. The Chancellor seems to be intent on a creeping tax grab from this sector and advice for now has to be that no tax rules on resi should be regarded as settled, and that further changes may come, none of them likely to be welcome. Whether this has a material long term adverse effect on the UK investment market, which is the fear here today, cannot yet be known. I would bet against it this time in the knowledge that this particular golden goose's death has been predicted many times before.

Following the changes announced to the personal taxation rules for company distributions in the Summer Budget 2015, the Government has now announced that it will publish a consultation on the rules concerning company distributions later in 2015. In addition, the Government will amend the "transactions in securities" rules and introduce a targeted anti-avoidance rule in order to prevent opportunities for income to be converted to capital in order to gain a tax advantage. It is understood that this will specifically target certain voluntary liquidation schemes. The transactions in securities rules were substantially amended (and simplified) in 2010 and changes to re-introduce added complexity would obviously be unwelcome. However, given the rate differential that will otherwise apply, the introduction of new anti-avoidance measures will not come as any great surprise.

On the plus side it looks as if the careful and diligent lobbying of HMRC on the extravagances of the Entrepreneurs Relief changes earlier this year will bear fruit, with the government "considering" changes to protect "genuine commercial transactions". But we don't know for sure, by when or whether any correcting legislation will be retrospective. The government will take forward "the majority of recommendations" by the OTS on employment status, but we don't know which ones. The government will "take action" against "disguised remuneration schemes" but we don't know what the target is and the thought of a new Part 7AA ITEPA can only make one shudder. And we are also promised a further consultation on the "rules concerning company distributions" and amendments to the transactions in securities rules (including a new TAAR) to "prevent opportunities for income to be converted to capital gains".

In summary, from a tax adviser's perspective this was more of an "Autumn Update on Work In Progress - Watch This Space Please" than an "Autumn Statement". A bit disappointing?

Not content with the myriad of taxes imposed on residential property over the past few years, the Chancellor is further penalising the buy to let sector by imposing a higher SDLT rate (at each tier above £40,000, an additional 3%) on purchases of such properties by individuals and, for other investors who do not have significant holdings in the sector. There is a sense that this is aligned with the desire to reduce the structural financial risks posed by the buy to let sector in the event of an increase in interest rates.

The announcements of further anti-avoidance rules continues unabated - the target now being increasing the penalties for avoidance (such as a new 60% penalty for avoidance under the GAAR), publicly naming serial avoiders as well as new criminal and civil penalties for tax evaders.

The Government also clearly feels there are still some areas where that individuals are able to benefit from lower capital gains tax rates on what is ostensibly income and will be introducing yet another targeted anti-avoidance rule in addition to amending the transaction in securities rules. In this vein, legislation is also to be introduced to treat returns of asset managers (presumably extending to carried interests) as subject to income tax unless the underlying fund undertakes long term investment activity.

Given that spending cuts (particularly the reversal on tax credits) were not as deep as expected, it is a little surprising that the Statement was not accompanied by more tax-raising measures. The most significant tax increase seems to be a £3bn per year apprentices levy on businesses which, together with a projected increase in tax receipts, appears to have given the Chancellor more room for manoeuvre than expected. Some interesting points have been trailed, with very little explanation, and will require close examination of Finance Bill 2016. Clearly the upcoming increase in the rate of tax on dividends has caused the Government to reconsider the scope of the "transactions in securities" rules, and this will need to be watched. There also seems to be a threat of potential retrospective legislation for disguised remuneration schemes, which also caught the eye.

Many of the statements on tax relevant to businesses were at a high level and we will have to wait and see whether they have a significant impact. Of note are the proposed changes to carried interest (draft legislation is now expected on 9 December), a new consultation on company distributions and yet another targeted anti-avoidance rule to be introduced alongside amendments to the transactions in securities rules.

There was little of interest for the oil and gas industry from a fiscal perspective. Discussions with government on fiscal measures to maximise economic recovery are ongoing and further developments are expected at the next Fiscal Forum with government ministers on 16 December.

For my native Northern Ireland, it was confirmed that corporation tax powers would be devolved with a rate of 12.5% being pursued. It will be interesting to see whether this results in a reinvigoration of activity in Northern Ireland, as well as observing the plethora of legislative changes that will be necessary.

The Government continues apace with its stated vow of tackling tax avoidance with proposals for further targeted anti-avoidance rules (e.g. capital allowances and leasing and disguised remuneration) and further expansion of the tools available to HMRC in respect of "serial avoiders" and the promoters of tax avoidance schemes (including more naming and shaming). Whilst this is to be welcomed it does arguably simply add yet further complexity to the tax system rather than addressing the root cause of the avoidance issue –the system itself and leaves taxpayers in a continued state of flux/confusion as to when it is legitimate to make tax efficient investments and whether the advice they may have received in respect of the same can be relied upon. Stewarts continues to receive requests for assistance from taxpayers concerning their investments in various schemes both in terms of HMRC's actions and those of the promoters/advisors of the schemes.

Entrepreneurs breathed a sigh of relief yesterday when it became clear that the widely predicted curtailment of entrepreneurs' relief was not on George's agenda. With the cost to the Exchequer of the relief having rocketed from £360m in 08/09 to £2.9bn in 13/14, many predicted a row back on the lifetime allowance. Whilst that would have been a difficult message for the pro-business Chancellor to deliver, one would be forgiven for thinking that a further tightening of the rules and some of the practices in this area would be more than justified.

The Government has, yet again, stressed its commitment to clamp down on tax evasion. Corporates in particular will be keen to understand the details of the proposed new criminal offence for corporates which fail to prevent their agents from criminally facilitating tax evasion by an individual or entity. They are particularly concerned about the extra territorial scope of the proposed legislation as well as the broad meaning of "agent". It is hoped that the draft legislation will seek to strike a fair balance between the interests of the state and the interests of corporate taxpayers.

Another Autumn Statement, another raft of measures with the aim of reducing tax avoidance: "Action against … disguised remuneration schemes and [those] who have not yet paid their fair share of tax.", "legislation to counter 2 types of avoidance", … . Further investment in the commitment to reduce avoidance. New measures announced to tackle tax evasion. As inevitable a mantra as "the sun rises".

It has been suggested that one of the key proposals will be the introduction of a tax-geared penalty of 60% where the GAAR has been applied. Given that, in its 2 years of operation, there has yet to be a case referred to the GAAR panel, the rationale for this proposal may well be pour encourager les autres, not revenue raising. This measure is projected to raise £10million in 2016. In terms of closing the tax gap, that is barely even a finger-nail in the dyke.

The criminal offence of failing to prevent tax evasion will be introduced. One of the key issues to be determined here is the standard against which a corporate will be judged, if it is held to have failed to prevent an agent from committing tax evasion; will "adequate" procedures (per s.7(2), Bribery Act 2010) be the test?

Restricted by the tax lock, the Chancellor has resorted to generating tax revenues‎ through increasing SDLT for additional residential property and bringing forward the payment deadlines for SDLT and for CGT on residential property. The concept of "additional" residential property will need to be carefully defined in practice. For instance, the charge should clearly not arise where someone buys their new home before managing to sell their old one. Separately, why is the CGT window being shortened only for residential property gains, if forgetfulness and inability to pay are the real causes?

No restrictions to entrepreneurs' relief were announced, despite press speculation. Instead, in a welcome move, the government appear to have acknowledged that some of the changes introduced earlier this year inadvertently caught genuine commercial transactions and so should be corrected.

The government's conclusion from their consultation on ‎the taxation of asset managers' performance-based awards seems to be that, although the traditional test of investment versus trading will still apply to the tax treatment of the fund, a higher hurdle will need to be overcome for carried interest (for instance) to benefit from CGT treatment: the investment strategy must be long-term. If so, this adds unwelcome complexity.

There were few surprises as most of the issues in respect of which legislation is expected have been the subject of consultation. There are a number of specific provisions designed to prevent identified tax avoidance schemes such as provisions relating to the deep in the money options and capital allowances so the volume of legislation is set to increase yet again when these changes are probably not required as the existing legislation is required to be construed purposively and applied to the facts viewed realistically. The proposal to review the taxation of dividends, the opportunities to convert income into capital and a proposed new targeted anti-avoidance rule is utterly unbelievable because the former anti-avoidance provision in this sphere was emasculated at the last review of the taxation of dividends. This highlights the lack of technical expertise and the lack of thought in HMRC. It is also lamentable that HMRC seem determined to tax compensation sums even though those sums may not represent any income or gain. This is likely to be the outcome of their further consultation. That the consultation is taking place at all is extraordinary given every single response to the first consultation on the topic opposed the idea.

The U-turn on tax credits and scaling back cuts to public services are dominating the headlines on the Autumn Statement. But in the background, changes were announced which will dominate the tax landscape for years to come.

For large businesses, the requirement to publicise their tax policies will, if it is enforced in any meaningful way, entrench the prevailing theme that Big Business is accountable not just to its shareholders but to its customers and the public at large for the way it pays its taxes. Cementing this into prevailing corporate practice would represent a sea-change in the British business landscape.

For individuals too, yesterday marks the beginning of the end of an antiquated tax payment system. In the future we will all have digital tax accounts, and real time payment of tax on capital transactions as well as income - two huge steps towards a transparent tax system which is understood by its taxpayers.

If only the Government would stop tinkering round the edges, with ridiculous measures such as differential rates of SDLT for different types of buyers, we would really be making progress.

From a private client perspective, the introduction of an obligation to pay CGT on residential property disposals within 30 days (albeit from 2019) and the additional 3% SDLT payable on the acquisition of "additional properties" were the biggest surprises. Of most concern was the announcement of a 60% civil penalty for avoidance countered by GAAR - which appears a little unfair when the GAAR rules make no provision for prior rulings. Advisers will have to take an extremely conservative approach to the GAAR guidance notes from April 2016.

We live in interesting times. With the prospect of a referendum on EU membership in 2017 casting doubt on the UK's position within the EU, Wednesday's Autumn Statement might be seen as containing glimpses of the future for the constitution of the UK itself. A Northern Ireland corporation tax rate, perhaps unsurprisingly set at a rate of 12.5% to match that of the Republic; further devolution of tax raising powers to Scotland; proposals for Welsh rates of income tax; and the abolition of the uniform business rate - all seem to point, at the very least, to a more fragmented, less centralized, dare we say it, more federal UK - and a more complicated tax system.

The new 60% penalty of tax due to be charged in all cases successfully tackled by the GAAR is a sign of a Government determined to up the ante in relation to tax avoidance. However, it is doubtful if the structure of the GAAR and its originally intended purpose sit well with this new penalty. HMRC may now be encouraged to deploy the GAAR in place of other avenues of challenge. Great stress may come to rest on what may reasonably be regarded as a reasonable course of action.

The Autumn Statement included relatively few pension announcements, although the lull is likely to be short-lived, as it was confirmed that the Government's response to September 2015's consultation on changes to pensions tax relief will be included in the March 2016 Budget.

The principal announcement was that the single-tier, flat rate State pension will start at a weekly rate of £155.65. This will replace the current basic and additional State pensions and will be paid to those reaching State pension age on and after 6 April 2016. For those already receiving the basic State pension, this will rise £3.35 to £119.30 from next April.

Confusingly, many will find they do not receive the full single-tier, flat rate at all. Those who have spent part of their working lives contracted-out of the State pension (and thereby paying lower National Insurance Contributions (NICs)) could find that they are due to receive considerably less than the headline rate of £155.65 when they reach retirement after April 2016. However, it will be possible in some circumstances for those affected to continue working extra years and contributing NICs after April 2016 in order to boost their State pension entitlement under the new regime. For each extra year worked, £4.43 per week will be added to the State pension, up to the maximum of the flat rate. State pension forecast statements can be requested from HMRC here.

Following consultation launched at the time of Summer Budget 2015, the Government has confirmed that they will legislate to introduce a new requirement that large businesses publish their tax strategies as they relate to or affect UK taxation; a special measures regime to tackle businesses that persistently engage in aggressive tax planning; and a framework for cooperative compliance. Assuming that the regime is implemented as set out in the original consultation document, it should only apply to the largest groups of companies - broadly those that currently fall within the scope of the Senior Accounting Officer regime. Whilst an increasing number of public companies have taken to publishing their tax strategies, for those that have not, and did not intend to, this will represent yet another compliance burden hot on the heels of country by country reporting and other transparency initiatives. For those companies with overseas parents where there may not be a requirement to publish anything under the parent jurisdiction domestic law, thought will have to be given to producing something bespoke for the UK.

The Autumn Statement affirms the Chancellor's standing as more the master of cumulative detailed tax-raising measures than a serious evangelist of austerity. There is little new for advisers to non-doms. The consultation on business investment relief will only enhance relief if the anti-avoidance is limited to the circumstances of the relief. The new strict liability criminal offence of failure to declare offshore income and gains has been confirmed for the Finance Bill 2016 but we are not expecting a response to consultation until the publication of the Finance Bill 2016 - it is important that the offence is not committed through a reasonable misconstruction of legislation.

The tax announcements had a particular focus on real estate. The Chancellor seems to be waging war on "buy-to-let" investors with the punitive SDLT rate increase following so closely on the heels of the interest relief restrictions. An exemption for "significant investments in residential property" seems to turn normal tax policy on its head (lower tax rates for larger businesses) and one has to ask whether it could be subject to challenge, e.g. under state aid rules.

The requirement to pay CGT on account on residential disposals may be to address enforcement issues on the extension of CGT to non-UK resident investors in UK residential property. Will selling solicitors/conveyancers be expected to deal with this and withhold from completion funds returned to the seller? Presumably if capital losses arise later in the same tax year, CGT paid on account will be repaid when a self-assessment return is filed?

Elsewhere, the lack of any new restrictions on ER is a lesson in not listening to gossip.

It is great to see the Chancellor embracing technology in his desire to create "the most digitally advanced tax administration in the world". There was an immediate sting in the tail however in the form of payments on account for capital gains on residential properties. Worryingly, this sounds like an idea which will catch on and may soon cover capital gains on a wider category of assets.

Solving the political brouhaha around cuts to the tax credit system while still balancing the books meant that the Chancellor needed to pull a proverbial rabbit out of his red box. The rabbit took the form of a significant increase in tax receipts forecast over the next five years, contributing to a £27 billion anticipated improvement of public finances since the last Office of Budget Responsibility forecasts in the summer.

Bigger business will contribute approximately £12 billion more to the Exchequer over the period by paying a new apprenticeship levy, a charge of 0.5% on larger employers' payroll from 2017.

Investment in combatting, and deterring participation in, the extreme, egregious end of tax planning is also evident: new civil penalties and criminal offences for participation in or enabling or failing to prevent tax evasion are to be created and tax-geared penalties will be strengthened for arrangements falling foul of the GAAR.

There was remarkably little rhetoric directly addressed at multi-nationals - BEPS fatigue perhaps? - though the implementation of BEPS conclusions on hybrids and consultation on interest deductibility are looming in the background.

The Finance Bill clauses and related papers to be published on 9 December will need careful scrutiny, in case there are more such rabbits lurking.

Good news for the commercial property sector - UK government efforts to crush the residential real estate investment market apparently continue, this time in the form of an additional 3% on SDLT rates for second homes.

The housing market is predictably apoplectic, cue statements of outrage from the relevant associations. But given that the announcement is yet another in a long line of measures that penalise the purchase and holding of residential property, this is perhaps not surprising. Developments in recent years include the higher rate of SDLT for enveloped dwellings (March 2012), ATED and ATED-related capital gains (April 2013), further increases in SDLT for residential property (December 2014), capital gains tax for non-residents (April 2015), the restriction of buy-to-let interest relief (to be phased in from 2017) and the inclusion of indirectly held UK residential property in the IHT net for non-doms (April 2017).

The piecemeal and fragmented approach is unfortunate. Many of the measures are forward-looking in any event. The implication is that somebody, somewhere is firing out missives as they occur to him or her. It does not suggest an organised and coherent approach to tax policy.

The effect of the announcement is to further increase the disparity between the tax treatment of residential and non-residential/mixed property. The distinction is already under pressure. We have heard of some quite eye-wateringly "creative SDLT arrangements" (a benign and politic description) looking to exploit the divergence. We can expect increasing HMRC scrutiny in this area.

The proposed increase in the rate of SDLT on the purchase of "additional" homes with effect from April 2016 was a surprise. Clearly the Government will need to get a move on with the consultation if it genuinely wants feedback on the scope of the new rules. In particular, the carve outs for certain "corporate or funds owning more than 15 residential properties" will need to be considered properly. Further, since the abolition of the slab system for residential property in December 2014, different rates of tax apply to residential property on different "slices" of the price - so you cannot simply increase a single rate by 3%. It appears that the proposal is for the rate of tax on each slice to be increased by 3% (not just the rate of tax on the top slice) - although this is not entirely clear. Whichever way you look at it, this is a big hike in SDLT.

I also think that the proposal to reduce the window for paying SDLT and filing a land transaction return from the current 30 days to 14 days is a bit mean - it will simply lead to lots of late returns! At least we will get a chance to say this in the consultation next year…

It is difficult to gage the impact of the key changes and measures given that in almost all cases, only scant information was disclosed. Practitioners will, therefore, have to piece together the precise meaning of the changes when Finance Bill 2016 is published, a now dreaded task. Experience suggests that the "devil will be in the detail" – and that we will therefore only know on 9 December after thorough study of the Finance Bill what Wednesday's announcements really mean – for example, when is carried interest treatment still available. Not a great way for HMRC (or anyone) to operate, given how much time was available. And - quite what HMRC had in mind when it chose only three (!) tax areas for inclusion in the "Main tax announcements for Autumn Statement 2015" is a mystery and makes one wonder what's going on at Whitehall and 100 Parliament Street. Yes, the three areas are among the most significant – but surely the de facto abolition of self-assessment for taxpayers with "simple" tax affairs from April 2016 deserves a mention, as do some of the policy changes for corporates.

With the Autumn Statement coming just one the week after the second Finance Act of the year received Royal Asset, tax lawyers could be forgiven a small amount of legislation fatigue. We have to wait for the draft Finance Bill clauses on 9 December to be sure, but the announcements on the day were relatively low key, particularly as most had expected more post-election belt-tightening: some had feared possible changes to entrepreneur's relief or employee shareholder shares.

The Chancellor did his best to present a brave face as he was forced into a U-turn on cuts to tax credits, but the £9 billion cost had to be clawed back somewhere. The 0.5% "apprenticeship levy" for employers with annual payroll costs exceeding £3 million is effectively a £3 billion per year rise in employer national insurance contributions, but with a smiling face. It remains to be seen how much will be recycled in training subsidies: many larger employers will face additional costs from 2017. The Chancellor also continued his penchant for tweaks to the timing of tax payments leading to one-off accelerations of tax receipts, with plans to reduce the time to pay SDLT, and proposals for payments on account of CGT on sales of residential properties.

This year's Autumn Statement proved to be rather quiet on the corporate tax front, contrasting with the recent OECD/BEPS led activity in the international arena. Perhaps this was in part due to the relatively recent Summer Budget and the fact that the Chancellor had benefitted from an unexpected revenue windfall driven by higher than expected receipts and an improving UK economy. As is typical in the current climate, yesterday's announcements covered a number of targeted anti-avoidance measures and made reference to the Government's desire to combat perceived anti-avoidance. In particular, we can expect legislation to determine when performance based rewards received by investment managers (such as carried interest) will be taxed as income or capital gains, which from a policy perspective seems consistent with what has previously been said. The major headlines were, however, made by issues that impact day to day life, such as the reversal of tax credits policy and attack on buy to let investors. UK businesses will presumably take some comfort from the Chancellor's attention being directed elsewhere.

The proposal to allow local authorities to keep the revenue from business rates and the ability to cut rates locally to stimulate economic growth is welcome news.

The announcement of the ability of those areas with elected mayors to raise rates to fund specific projects is good news. What is disappointing is that this power is restricted to areas with elected mayors. One size does not fit all and the linking of additional powers to areas with an elected mayor risks embedding a two-tier model of devolution which hinders the ability of those areas for which an elected mayor is not the right answer to achieve the levels of growth which they aspire to and are capable of delivering.

This has been a rather underwhelming Autumn Statement by the Chancellor from a tax perspective which I suppose is a good thing given the sheer size of recent Autumn and Budget Statements. After a number of years, non-domiciled taxation did not feature prominently in this statement and no substantive announcements have been made in relation to the ongoing proposals to change non-domiciled taxation. Whilst the overall message on the UK's economic recovery is positive, the Chancellor's penchant for prudence is still in evidence with new tax raising measures continuing to be introduced. Residential property continues to be a soft target for tax raising - an increase to the increased SDLT has been announced for second homes. Also, the UK Government's obsession with anti-avoidance rules does not seem to abate - there has been a raft of further measures but I suppose this a small price to pay for a more streamlined and technologically advanced HMRC which has also been promised within the life of this parliament.

The glass half full view of employee share plans, based on a brief para 3.24 Autumn Statement mention, is that their policy value clearly remains recognised by the UK Government and any necessary technical tweaks, e.g. to help internationally mobile option holders, will continue to be made. However, counteracting tax avoidance remains at the forefront of this Autumn Statement including reviews of salary sacrifice arrangements and contrived entrepreneurs' relief structures together with further action on earned remuneration avoidance schemes and a new targeted anti-avoidance provision in the transactions in securities rules. Perhaps the new partial exemption for charitable trusts from the loans to participators rules keeps open the potential for an additional technical tweak to exempt loans to employee trusts from these rules. This would help maintain the current UK growth of the employee ownership business model. I'll drink to that.

In an Autumn Statement in which the Chancellor otherwise had little to say in respect of corporate taxation, he announced two important changes to how the intangible fixed asset (IFA) rules will apply to the transfer of IFAs between partnerships (and LLPs) and related parties for corporation tax purposes. The first measure seeks to ensure that IFAs created prior to 1 April 2002, and which have not been acquired from an unrelated party since that date, will not qualify for amortisation relief on being transferred to a partnership by a related company (or vice-versa). The restriction of amortisation relief will have immediate effect from 25 November, without any grandfathering for transfers before that date. The second measure will seek to ensure that the transfer of IFAs that have been created or acquired from an unrelated party since 1 April 2002 between a partnership and a related party will be treated as taking place at market value. This measure will apply to unconditional transfers taking place on or after 25 November. The Chancellor characterised these changes as anti-avoidance measures, and HMRC (which regards the changes as "clarifications") has said that they do not consider that the arrangements which they are designed to counter work in the way that is claimed. This announcement comes on top of the recent measures enacted in the Finance (No. 2) Act 2015 which restrict the availability of amortisation relief on the acquisition of goodwill and customer-related intangibles across the board and tightened up the intangibles exit tax rules. The transitional rules of the IFA regime have been subject to continual controversy and tinkering since they were introduced in 2002, so the Government's commitment to consider a review as part of the Business Tax Roadmap will be welcome to many. Less enthusiastic will be the parties to commercial joint ventures that have been caught in the cross-fire over the years.

The changes/clarification to the corporation tax treatment of intangibles held by partnerships will, I suspect, catch many innocent transactions. There seems to be a perception that all companies engaged in partnerships are trying to avoid tax, which is just not the case. The existing rules are in fact ill-defined and overly complicated (as can be seen from the FTT decision in Armajaro) and this gives rise both to opportunities to abuse the rules as well as unexpected taxation. The whole area of how the corporate intangibles rules interact with the partnership/LLP rules requires clearer legislation or at the very least a statement of practice along the lines of SP D12 that would clarify how the rules are meant to operate. Introducing measures to "stop arrangements that use partnerships to obtain relief that was not intended" when the intention of the legislation is (to my mind at least) far from clear seems to be the wrong way to deal with this.

Recent governments have carried out something of a crusade against so-called disguised remuneration. Nevertheless, the Autumn Statement contains a rather robust, if somewhat generic, statement that the Government intends to take action against those who have used or continue to use disguised remuneration schemes and "who have not yet paid their fair share of tax". As a warning to those that continue to engage in tax planning in this area, Government will stressed that it would consider legislating retrospectively in future Finance Bills to close down any further new schemes intended to avoid tax on earned income, where necessary, with effect from 25 November 2015.

Yesterday's tax announcements might be considered to be more a Teaser than a Statement, with little detail and so little ability to assess whether there will be significant changes or mere tinkering with the rules around things like company distributions, internationally mobile employees and employment status. It does appear, however, that there will be a busy period of consultation and the statement that work on the BEPS-related hybrid mismatch legislation will commence soon is the first element of what will no doubt be a significant piece of work for both the government and interested parties. What is of interest is the 60% penalty for schemes successfully challenged under the GAAR, which highlights the important distinction between "abuse" and "avoidance" in its name and it is hoped will convince both the government and the independent GAAR panel that it should only be used in appropriate cases and not as a general weapon against arrangements that HMRC might find distasteful.

Aside from another slew of anti-avoidance announcements and a further assault on second homes and buy-to-lets, it was a relatively low key affair, especially on the corporate tax front - about time (it won't last)!

"Apprenticeship" is a virtuous word and "levy" is more quaint than "tax", but the new payroll tax is a big deal. There is a £3m pay bill threshold, but it will add 0.5% to the tax bill of many businesses from April 2017, particularly people-heavy ones - like beleaguered retailers, which already have to manage the living wage. The tax is expected to raise over £11bn over five years.

The Government aims to reduce opportunities to convert income to capital gain for tax advantage. Consultation on the company distribution rules is due this year, and amendments to the transactions in securities rules, together with a new TAAR, will be included in Finance Bill 2016. The intention may be to address specific structures, involving voluntary liquidations, but having narrowed the TiS rules, a re-widening of them is unwelcome, risking uncertainty for routine transactions.

More promisingly, the Government will consider amending the FA 2015 changes to entrepreneurs' relief to ensure availability for certain "genuine commercial transactions". If the changes preventing "ManCo" structures from qualifying could be made more focused, that would be good.

More generally, the digitisation of tax administration, reiterated on Wednesday, is inevitable. Will tax payment dates, other than just CGT on residential property disposals as currently announced, be accelerated towards the taxable event…?

The planned introduction of tax geared penalties of 60% for the general anti-abuse rule (the GAAR), increases the ferocity but not necessarily the effectiveness of the regime, still comparatively in its infancy. With still not a single reported case going before the GAAR advisory panel there is still very little certainty as to when in practice the GAAR would bite, if at all. Therefore it is reasonable to ask whether these changes are intended to act as anything other than a deterrent, presumably to encourage taxpayers to settle on other terms.

Mercifully little to digest this time, but it will be worth keeping an eye out for the consultation on company distributions. HMRC has felt for some time that the existing caselaw rules for determining whether distributions are income or capital in nature: which look to legal form: afford taxpayers too many planning opportunities to convert income into capital or vice versa. This consultation may signal its wish to adopt an approach which looks to the underlying substance of the receipts. Quite how that would work is anyone's guess, particularly for minority shareholders who have no way of analysing the character of the receipts out of which distributions are made. Assuming it is too difficult to craft a "one size fits all" substance-based definition of distributions without creating huge uncertainty for taxpayers, the more likely result may be more TAARs to attack intra-group or connected party arrangements that HMRC deems offensive.

There is a raft of tax avoidance legislation proposed, some resulting from consultation over the summer such as the measures to improve large business compliance, others to be introduced after consultation such as the proposed TAAR in connection with company distributions where arrangements are entered into to secure capital rather than income distributions. No doubt the new legislation, in keeping with the current trend in TAARs, will be very widely worded with accompanying guidance containing examples of 'good' transactions. A key question is whether the framework for cooperative compliance for large businesses will be a voluntary code or statutory.

The introduction of a 60% penalty of tax charged in all cases following a successful GAAR challenge rather undermines the requirement under the GAAR that the counteraction of the tax advantage should be "just and reasonable".

While practitioners are puzzling over the implications of the Supreme Court decision in Anson v HMRC and the HMRC response to that decision, the Government has reaffirmed its commitment give effect to the OECD BEPS Action 2 on hybrid mismatch arrangements. Finance Bill 2016 will introduce rules to take effect from 1 January 2017 in order to counteract the avoiding of tax through the use of certain cross-border business structures or finance transactions.

For many years, the UK has already had an array of measures in this area including, equity note provisions, the anti-arbitrage legislation, and dual resident company rules. The very modest amounts of increased tax yield projected for the new proposals makes one wonder why the deck is being reshuffled. Since the OECD Action 2 has only produced recommendations, the changes will not necessarily result in international harmonisation in this area.

A more welcome approach would be to grasp the nettle of entity characterisation so that disparities with other tax systems do not cause double or multiple taxation, as well as counteracting the identified avoidance.

The love-hate relationship with non-doms continues. Since 2008, the remittance basis has been progressively narrowed in its application and its rules made impenetrably complex. While the tax regime ironically permits foreigners to live in the UK with limited tax on their foreign income and gains, it also perversely disincentivises them from investing in the UK economy.

The planned consultation on changes to business investment relief so as to encourage inward investment by non-doms aims to address that inconsistency. A joined up policy would also encourage longer term investment horizons by re-evaluating the proposed 15 year cap on access to the remittance basis.

The consultation process on hybrids announced in December 2014 was supposed to be followed by the publication of responses in summer. Instead we are simply steaming ahead. As things stand the UK will be the first mover in introducing rules based on the OECD proposals to counteract hybrid debt and instruments. Although Australia announced its own consultation within the last week (bit of a pattern here - first we introduce a diverted profits tax, then they do) there seems to be less of a commitment to implement the rules in Australia, and in any event they would not bite there until July 2017 at the earliest.

The absence of any motive/tax avoidance test makes it critical that the new rules are tightly drawn, but as the OECD draft stands the thresholds are just too low - effectively assuming the mischief is not so much BEPS within a multinational group as hybridity itself.

The big outstanding questions include whether CFC inclusion of income will "frank" a D/NI outcome and the thorny question of hybrid regulatory capital. But overall the hunt will be on next year for effective replacement debt structures - maybe moving towards tax rate arbitrage rather than a hybrid outcome.

The Autumn Statement confirmed that the Government will be taking forward its proposals with regard to the tax treatment of performance-linked rewards received by asset managers, without providing any more detail at this stage. The Government's suggested policy is to ensure that an award will be subject to income tax, unless the underlying fund undertakes long term investment activity. It remains to be seen, however, whether the proposals reward such long term investment across all sectors of the fund industry. There has been much lobbying behind the scenes and the release of draft legislation on 09 December 2015 will reveal much more about the detail of this measure.

Tax avoidance and tax evasion predictably featured prominently in the Autumn Statement with the Government announcing £800m to fund additional work to tackle evasion and non-compliance by 2020-21. Indeed, the Government is committed to raising an additional £5bn a year through tackling avoidance, aggressive tax planning, evasion, non-compliance and "imbalances in the tax system" by 2019-20 - though the law of diminishing returns must come into play at some point!

In particular, the Autumn Statement announced a number of new anti-avoidance measures as well as confirming that proposals concerning additional GAAR penalties and tougher sanctions for offshore avoidance will be taken forward in the Finance Bill. The Government also confirmed that the proposed Orwellian Code of Conduct on tax compliance for corporates will go ahead, together with a new and controversial criminal offence for corporates failing to prevent facilitation of tax evasion.

Leaving aside John McDonnell's spectacularly inept (but comical) inclusion of the works of Chairman Mao in his response, and the equally spectacular upward revision of tax receipts with the Tax Credit climb-down it permitted, there was not much genuinely outstanding on the tax front.

A few disappointments - 0.5% NOTNICs to fund apprenticeships raises a lot of tax revenue but rather undermines the "Tax Lock"; a plethora of TAARs shows a depressing lack of imagination; and there's been a disappointing absence of movement on a few consultations - what, really, is the benefit to anyone of a series of similar, anodyne tax strategies, for example?

Good news that the rumours concerning Entrepreneurs Relief and Employee Shareholder Status did not prove correct. But in a number of areas we are still waiting for potentially serious bad news - including on fixed ratios for interest relief, a consultation on company distributions and changes to the tax treatment of carry, all of which have the potential for tax treatment to affect behaviour in an unhelpful and inefficient manner and to have broad reaching consequences. I am not sure I am optimistic where these will each end up.

It's hard to think of an area of tax law where there have been so many changes over such a relatively short period of time as the taxation of UK residential property. In the space of just a few years we have seen increases in SDLT rates, the introduction of the ATED and ATED-related gains regime, the extension of capital gains tax and proposed changes to mortgage interest relief, wear and tear allowances and the inheritance tax regime for properties held through non-UK companies. Yesterday's announcement sees further changes with a proposed acceleration in the timing of the payment of tax on capital gains on residential properties as well as the headline-grabbing 3% surcharge for individual buyers of additional homes such as buy-to-let and second properties. The 1 April 2016 implementation date is likely to fuel a surge in the property market over the next few months and it will be interesting to see whether over the longer term the change will have the desired effect of cooling the market or whether, when combined with the phased restrictions on mortgage interest relief (from April 2017), it will simply result in higher rents as landlords pass on their increased costs to tenants. The Government intends to consult on whether there should be an exemption for corporates and funds owning more than 15 properties which, if introduced, would distort the market in favour of larger investors.

The Autumn Statement itself has been as empty of news as any in recent years. This is, despite significant pre-Autumn Statement tension this year on possible changes to IR35 and the withdrawal or scaling back of entrepreneurs' relief or employee shareholder status, the last of which is now gathering momentum and becoming a feature of much management incentivisation.

9 December - the day on which the draft Finance Bill is being published - is more likely to be an interesting day. though as HMRC will then produce provisions making sure that all share awards to internationally mobile employees are taxed (and more importantly subject to National Insurance contributions) under the new regime introduced for them last year, removing some of the harshness of the entrepreneurs' relief changes introduced earlier this year, and, as proposed in a consultation paper earlier this year, further restricting how investment managers can realise capital returns (though tantalisingly not giving away exactly how). A number of other simplifying, technical changes for employee share schemes are also proposed promised.

In due course, details will also come out changes on how travel expenses for services provided through intermediaries can be claimed for on a tax deductible basis, possible changes to the termination payment regime and provisions clarifying employment status will emerge. However, but it is certainly business as normal usual for the moment, which is a relief.

Constant change is exhausting for advisers and companies alike, and because share scheme advisers now have the best range of tools to use for client purposes which they have had for some time, we should be grateful to keep what we have in the current environment.

With this year's Finance Bills and potential major changes on the way under the guise of the BEPS initiative, it was not surprising that there were few new measures announced; the main focus from the business tax point of view was on confirming what measures would be included in next year's Finance Bill. One of the few measures was an anti-avoidance rule in relation to the 1.5 per cent charge on depositaries and clearance service operators, a mere 6 years after the ECJ took away one of the pillars of the regime. The continued focus on anti-avoidance is not surprising with the Government intending to legislate this summer's package designed to force boards to play their part; it will be interesting to see to what extent companies adopt the tax strategy proposals in full ahead of the proposals being implemented.

Some incremental details have been provided on two measures that have been widely anticipated in the run up to the Autumn Statement. Interestingly, both featured under the umbrella of "tax avoidance" in the HM Treasury publication.

The first relates to the further confirmation that there will be a consultation later this year on the rules concerning company distributions. Until now it was not clear what this consultation might be getting at, but its inclusion under the heading of "avoidance" implies that this is not going to involve a general review of the treatment of dividends and other distributions. There is even a suggestion that it falls within a package of measures designed only to reduce opportunities to convert income into capital. It is to be hoped that the consultation is indeed that narrow in scope.

The other is the treatment of performance awards/ carried interest received by asset managers. It has been confirmed that this will result in awards being subject to income tax unless the underlying fund undertakes "long term investment activity" – but what everyone wants to know of course is what that really means. It is more difficult to see how this will be limited to addressing avoidance.

The most noticeable aspect of yesterday's Autumn Statement was the lack of new tax proposals announced. It may be that the Government is holding off on significant new business tax changes until the release of the business tax roadmap, expected by April 2016.

In any event, we can expect more detail on 9 December, when the Government will release draft legislation for numerous proposals consulted on over the past year. These will include new measures for persistent users of tax avoidance schemes, and changes to the GAAR rules (including a penalty regime), both first announced at the March 2015 Budget.

From a legal perspective, both sets of proposals caused concern. In particular, the lack of taxpayer appeal rights against the issue of a "warning notice" (the first step on the road to designation as a persistent avoider) was inappropriate given the serious consequences that could flow from such a designation: it remains to be seen if HMRC will change this.

In relation to the GAAR, it looks like HMRC will press ahead with a proposal that a GAAR advisory panel opinion on an avoidance scheme could bind a range of users of that scheme. This is very concerning: the non-judicial nature of the panel, its lack of resources to hear cases in the same way as a court, and the fact that not all panel decisions will be published, suggest to us that its opinions should not be able to bind other taxpayers in the same way as a court ruling.

Anyone reading today's Autumn Statement papers could be forgiven for looking at the measures listed under "Business Tax" in HMT's summary and thinking "nothing to see here, move along, move along". Two nuggets tucked away in there to give us all indigestion. One - the beautiful new stealth tax on employers called by the innocuous name of the "apprenticeship levy" - not apparently a tax charge on those who use cheap labour and call them apprentices rather than giving them proper jobs, but a de facto increase in employers' NICs by 0.5%. You've got to love this Government - so sneaky. Two - restitution interest, it is confirmed, will be taxed at 45% (yes, that's 45% everyone). Any readers who litigate will already know about this, but to corporates (and some corporate advisers) this may come as a shock. So when HMRC rips you off and nicks your cash, and you finally get it back plus compound interest, you can expect to only get 55% of the interest amount you're due, because HMRC are going to nick the other 45%. Oh, the diabolical audacity of sticking it in the Finance Bill No 2 at the last minute!

Overall, the various measures announced seem to be targeted at two things: raising money to reduce the deficit and moving the Conservative Government more towards the political middle ground, even possibly slightly centre-left. Many of the tax avoidance measures appear to be money-raising, as does the additional 3% SDLT on additional residential property purchases. The latter seems to be a "Robin Hood" style measure, which might also be said of the apprenticeship levy, applying as it will to larger employers representing only 2% of all UK employers (according to HMRC's analysis).

One of the themes of the Autumn Statement seems to be second (or sometimes third) thoughts.

It's good to see that the Government may mitigate some of the effects of changes which came in earlier in the year to entrepreneurs' relief and the special CGT regime for non-residents who dispose of residential property. Renewed tinkering with the distributions code, yet more focus on "performance based rewards" and a possible reversal of some of the simplification of the transactions in securities rules will be rather less welcome.

Worst of all, the Government is already reneging on an important promise made when the GAAR was enacted, introducing a 60% penalty charge so that the legislation operates in terrorem rather than simply as a fallback means of ensuring that "egregious and artificial" schemes do not work. This is particularly problematic when the basic test ("was it a reasonable course of action?") is so unsatisfactory. The optimist in me wonders though whether the impact on judges could be similar to the effect that the existence of the death penalty was said to have had on juries hearing murder cases in the years leading up to its abolition.

And one area which really needed further attention is not going to get it. In March this year the Government announced material reductions in the tax burden for North Sea operations. But with oil prices apparently stuck at levels which make much of the North Sea uneconomic - witness the 94% fall in tax receipts - there must surely be more help for this sector.

The Chancellor is clearly looking to discourage buy-to-let investors. You have to feel sorry for pensioners and savers who had planned to put their money into residential property investments. First he proposes to take away higher rate income tax relief on interest payments and now he wants to make them pay an additional 3% SDLT on top of normal SDLT rates when they acquire residential properties to let. If that wasn't enough, he wants to accelerate the date on which they pay CGT to 30 days after disposal (from April 2019) rather than the normal payment dates for self-assessment tax returns.

The additional 3% SDLT rates on second homes and buy-to-let residential properties are going to raise a number of issues. Presumably the test of whether the new rates apply will depend on the circumstances of the buyer and its purpose in acquiring the property, but what if those circumstances change after acquisition – can we expect another clawback period? The scope of the exemptions will also be a matter of concern for small property companies and unauthorised funds which hold less than 15 properties (presumably authorised funds and institutional investors will generally be exempt).

Rather than encouraging first time buyers as the Chancellor hopes, it is more likely that dealings in the secondary market for residential property will slow further.

It appears that the Government just cannot resist tinkering with the tax-advantaged venture capital schemes. Following the extensive changes which have battered the VCT and EIS industry over the past months, the Government made a further announcement in the Autumn Statement that as from 6 April 2016 all remaining energy generation activities will no longer by qualifying activities under the Enterprise Investment Scheme, Seed Enterprise Investment Scheme, Social Investment Tax Relief and Venture Capital Trusts legislation. Whilst this change will clearly be another significant issue for companies that carry on those activities I suppose we should be thankful that there were no other changes!

Whether the Government's offer of introducing increased flexibility for replacement capital within the EIS and VCT legislation ever makes it into law remains to be seen. Given that the Government has made it very clear that this is subject to EU State Aid approval, the cynic could be forgiven for thinking that this is no more than a late attempt to repair relations with a bruised industry which only has a low (possibly, no) chance of ever getting State Aid approval. Only time will tell whether such a viewpoint is realistic or overly cynical!

The proposal to counter stamp schemes involving deep in the money options looks narrowly targeted - and gives no indication that HMRC contemplates any wider revamp of the stamp regime applicable to depositary receipts systems and clearance services, to work around the hole still left by the HSBC decisions.

A warning that the government will consider legislating through future Finance Bills to close down schemes to avoid tax on earned income, with retrospective effect to this week, has echoes of the 2004 Primarolo statement.

Wasn't the government meant to be simplifying employment taxes? There is no update on the proposals to merge income tax with NICs - but, disappointingly, confirmation of a move in the opposite direction. The apprenticeship levy looks very much like an increase in employers' NICs - but, of course, to increase NICs would be to break an election promise. The politics are understandable, but it is a shame that, as well as having to pay the levy, businesses will be left with another tax to administer.

Following the Chancellor's autumn statement, many in the pensions industry will heave a sigh of relief that pensions aren't making the headlines. However, for the committed there are two notable developments that catch the eye. The first is the announcement that the next two increases in automatic enrolment will be deferred by 6 months. This will be welcomed by businesses across the land, large and small. The second is that we have been given much more on the Government's plans for the creation of what it is calling "six British Wealth Funds". With assets of at least £25 billion, these are the intended outcome of the proposals for investment pooling by the 90 or so funds in the Local Government Pension Scheme. Beyond that, it is what was not said by the Chancellor which is interesting. He has not revealed his hand on potential reforms to the pensions tax relief regime (that will come at Budget 2016), nor has he given any indication yet of where the current scrutiny of salary sacrifice is leading. Also, the hopes of those seeking a U-turn on the new tapered annual allowance for higher earners were dashed. This remains a big development for pension funds and employers, which is now on the very near horizon.

Even though it was a relatively unremarkable Autumn Statement from a tax perspective, there were a few property tax announcements to note. A key announcement was that a higher rate of SDLT will be payable from 1 April 2016 on second homes and buy to let properties but corporates or funds making significant investments in residential property will fall outside of the new charge. This continues the Government's attack on private landlords having already announced plans to restrict interest relief and to replace wear and tear allowances with a more restrictive relief.

The Government also a clamped down on certain capital allowance schemes with effect from 25 November 2015.

Given recent history it makes a pleasant change to have no measures of real technical interest announced on the big day. Instead we got to marvel at George Osborne's apparent discovery of a big bag of Magic Money Tree seeds, enabling him to crawl out of his self-dug hole on tax credits.

Over in the tax sphere though, I can't help wondering why when Labour last increased employer's National Insurance it was a pernicious tax on jobs, but when this government imposes a 0.5% tax on payrolls it is an equitable contribution to the cost of apprenticeships. I fear this won't be the last all new tax we see doing exactly the same as an existing one given the legacy of legislating to ban increases in income tax and national insurance.

There are clearly horrors in the pipeline though. A review of the transactions in securities rules is promised, along with an associated targeted anti-avoidance rule (confusing those of us who thought the transactions in securities rules were a targeted anti-avoidance rule). The carried interest changes are coming, we can only hope in a form much revised from the options in the consultation. And finally, and perhaps most scary of all, we have the consultation on restricting interest relief which has huge potential to damage UK PLC if mishandled. So watch this space…

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