Having substantially limited, in the last Budget, the tax advantages of employee shareholder shares, it came as a surprise that the government is now abolishing them altogether. This stems from these arrangements not being used as originally intended. This will be disappointing for companies, particularly private equity backed portfolio companies, that cannot typically use tax-advantaged share plans to incentivise management. Perhaps this will prompt a relaxation of the restrictions that prohibit many companies from operating such plans.

On termination payments, it appears that the government have woken up to the fact that the so-called "simplification" of the tax treatment of termination payments was anything but that! The first draft of the legislation which was published in October 2016 was complex and deemed certain components of a payment made on a termination to be earnings. We expect the redrafted legislation to clarify that only basic pay that would have been paid during a notice period that is not worked will be taxed as earnings, with everything else potentially being taxed as a termination payment. This should make it much easier for companies and individuals to ascertain the final tax position.

I think that the best thing about the Autumn Statement was that it was so boring, with virtually nothing we didn't expect in it! Long may that continue.

On the non-dom reforms, we had confirmation that these will go ahead from 2017. Hopefully this may silence the naysayers who still cling to the belief that the reforms are too difficult to implement in time and will be delayed until 2018. Clients need to take action now.

The promise of reform of the technical rules for business investment relief (BIR) for non-doms looks to be promising. The Chancellor seems to have hit on BIR as one of the sweeteners to the overall non-dom package which will, he hopes, keep non-doms in the UK.

We also had hints of a softening of the position for offshore trusts created before individuals become deemed domiciled in the UK ("protected trusts"). Back in August we were told that such trusts would lose their protection if the settlor or close family members enjoyed a benefit. While we await the legislation on 5 December to confirm the position, this hints that the Treasury may have accepted the professional bodies' alternative proposals which were widely circulated in September.

The lack of any anti-forestalling measures for the non-dom reforms was expected, but nonetheless welcome.

We need a stable and competitive tax system to ensure that the UK can retain its reputation as a good place to do business. This objective appeared to be at the forefront of the Chancellor's mind in his first and last Autumn Statement.

It was very welcome to see a change in the way the Treasury will now report on fiscal matters, doing away with the Autumn Statement as we have known it for many years and replacing it with an Autumn Budget and spring statement. This new regime, in which tax changes will now be announced in advance of the tax year and only once a year, will help to give businesses and investors the certainty and confidence they need to invest today in the UK. We saw support of UK R&D in the Autumn Statement as well as simplification of the substantial shareholders exemption but we would like to see this go further to other targeted tax breaks - including reliefs for entrepreneurs and reliefs that encourage growth and investment in the digital business sector.

Sometimes you have to be prepared to admit you got something wrong. And when you are new to a job, and you rose to the position through a series of unexpected circumstances, there is every opportunity to rectify those mistakes and blame your predecessor. The new Chancellor used the Autumn Statement to primarily confirm that not much will change, and mistakes of the past will be pushed through regardless. So the UK will continue to be first mover on BEPS, regardless of Brexit and the impact on our competitiveness. We will push through interest restrictions and loss relief, even on financial services businesses who are disproportionately affected. And HMRC will continue to try and make third parties (including advisers) police tax payer behaviour, even to the point where it prejudices the ability of tax payers to obtain independent tax advice because of things like the enablers proposal. Of course, at this stage we have no draft legislation to comment on, but recent history tells us that is when things usually get worse.

On the positive side, the Government will make changes to simplify the Substantial Shareholding Exemption ("SSE") rules. The Government is also considering bringing non-resident companies receiving taxable income from the UK into the corporation tax regime, which is potentially a sensible way to simplify the UK regime.

The £2bn annual fund to support R&D investment will take time to trickle through. Companies love R&D reliefs; they are genuine triggers that boost investment in innovation and technology. However, the £2bn figure is misleading. R&D reliefs are a form of EU state aid rules and it would be difficult – if not impossible – to see how the Government can action this pre-Brexit without it being detrimental to the UK's negotiations with the EU. The devil will be in the detail but, realistically, there will no action here until we have triggered Article 50.

The Chancellor acknowledged the scale and complexity of UK tax legislation when he announced his first real tax simplification action – having just one major fiscal event each year from 2018, the Autumn Budget. Businesses will welcome this move. Again, the impact won't be immediate but it is a step in the right direction and will make it easier to plan for the long-term, could improve the quality of legislation and result in less frequent change for businesses.

He also touched on the alignment of employees' and employers' national insurance thresholds - but Hammond could have taken it much further to align income tax and national insurance rules. More than half of the businesses we recently polled had this as their number one simplification measure to help reduce the administrative burden and bring employment taxes into the 21st century. Businesses will be disappointed that more wasn't done to progress tax simplification. UK tax legislation is almost 20,000 pages long. From a business perspective, the sheer volume and complexity of tax law is a major obstacle to growth.

It is rumoured that every £1 invested in infrastructure results in £3 of economic activity so I can see why infrastructure, infrastructure, infrastructure was the order of the day. Boosting productivity and bridging the gap with G7 nations will benefit businesses and workers in the long term. However, the productivity puzzle is a tough nut to crack and the Government must realise that it's not just about innovation and infrastructure; it's about getting more by doing less. Making things simpler, helping businesses navigate the system and eradicating out-dated laws that make tax more taxing can only help growth and prosperity in the long term.

The government has obviously given up trying to apply the new interest and loss restrictions to non-resident companies paying income tax. Instead it will consult on taxing those companies under the corporation tax regime.

The obvious question is how capital gains will be treated? At present non-residents are generally exempt from capital gains tax, with the exception of gains on residential property, whilst UK companies pay tax on equivalent gains. For that reason investment assets are often held through offshore holding structures.

If that changes, non-resident companies could be disadvantaged when compared with other non-residents. But that issue could be addressed through changes to the substantial shareholding exemption.

The abolition of the tax advantages associated with employee shareholder status (for arrangements entered into on or after 1 December 2016) was the big news for incentives lawyers. Philip Hammond's announcement clearly sounds the death knell for the future of employee shareholder status (and indeed the government has announced its intention to close employee shareholder status to new arrangements at the earliest opportunity). The tax advantages of ESS were significantly limited only in the Budget earlier this year, when an individual lifetime limit of £100,000 was introduced. It is therefore a little surprising that the Chancellor has fully withdrawn the advantages barely eight months later.

At least the measure set out in the accompanying policy paper and draft clauses acknowledges that independent legal advice may have been received in the few days and hours leading up to the Chancellor's Autumn Statement announcement, and permits such individuals to potentially still receive the income tax and CGT advantages they were expecting.

In the employee tax context, as widely predicted in the press, the government is pressing ahead with its plan to remove the tax advantages of certain salary sacrifice arrangements from April 2017. As would be expected, salary sacrifice arrangements in respect of certain benefits that the government wishes to encourage employers to provide (such as pensions, childcare and cycle to work schemes) are to remain. However, the removal of the advantages of other benefits, like health screening and gym membership, perhaps doesn't fit well with the Government encouraging "healthy behaviours".

There was little further detail on the proposals to simplify the tax and national insurance treatment of termination payments. Given the significant concerns raised by many about the draft clauses which were published as part of the consultation earlier this year, it is to be hoped that the final legislation achieves the stated objective of simplification!

There are positive developments in relation to real estate investment. The announcement of an extension to the Substantial Shareholdings Exemption, particularly for institutional investors, will hopefully include qualifying property businesses and introduce more flexibility in real estate holding structures. The clarification of the tax treatment of co-ownership authorised contractual schemes ( CoACS) will help in making the CoACS a viable structure option. There will though be some uncertainty around the effect of the consultation on applying corporation tax to UK income of non-UK companies and whether this will impact on the tax position of existing real estate investments held by offshore companies.

Buried in the Green Book (para 4.26) is a proposal that non-resident companies receiving taxable income from the UK will be brought into corporation tax. Conceptually and structurally this would be a radical change. Evidently the target is UK source income (beyond PE trading income which is already within CT). So that could include real estate rents (watch out offshore property companies), non-PE trade, royalties and interest, at least where not relieved from UK source taxation by a treaty (or, transiently, the EU Interest and Royalties Directive - but then income tax deducted at source should be creditable/refundable?). CT at 19% and the forthcoming 17% rate will be attractive relative to 20% income tax, but at the price of complexity including e.g. the full rigour of the loan relationship and derivative rules, rules on losses, the new interest cap and rafts of anti-avoidance. One might hope that 'income' does not include capital gains...

The statistics on current and projected tax receipts on page 58 of the Green Book are ‎a reminder of where tax is really paid. For 2015-16, out of a total tax take of £629bn, income tax and NICs provided £283bn (45%), VAT £116bn and CT £44bn. Fuel duties, business rates and council tax were also big players in the £27-29bn range per tax. The projected growth in tax take through to £800bn in 2021-22 (>4% CAGR) looks rosy, despite political controversy concerning perceived OBR gloom.

The most welcome news was the move to having only one large set of tax policy announcements per year. Hopefully this will improve rather than impair the quality of legislative amendments and technical consultations, though it remains to be seen whether government will really be able to resist more frequent ad hoc tinkering. The next most welcome was the lack of big surprises on the day. The writing had been on the wall for ESS, so its effective abolition for new entrants is not a particular shock.

It is a bit disappointing to see the BEPS interest restrictions still being pushed through in April despite the weight of technical objections raised and concerns about the economic effect of Brexit. One oddity is that it looks like the restriction will not apply to offshore landlords unless and until these are converted into CT payers, which could create a strange (though temporary) distortion. More positive was the brief suggestion that government will consider reducing the tax burden on the financial services sector in light of the Brexit referendum decision. That would be a welcome move, though potentially quite hard to implement politically.

Finally, there are a few interesting points scattered through the numbers published, not least the earmarking of £7.5bn for tax litigation over 5 years.

On the Indirect Taxes front, hints of a sweetener in the form of a 'VAT Giveaway' did not materialise. Draft legislation on the Soft Drinks Levy will be published in December. The freeze on fuel duty, however, is welcome.

The relief felt in the insurance sector by the government's earlier promise of a crackdown on fraudulent insurance claims was somewhat offset by a hike in Insurance Premium Tax to 12%. Along with recent case law developments, which narrow VAT exemptions for certain outsourced services, this is bound to lead to a rise in premiums.

The announcement of a Consultation on the future of VAT grouping may lead to a system which allows non-corporate entities to be grouped for VAT purposes with corporates.

The Retail Export Reliefs Scheme will go digital, which should streamline procedures and reduce false claims.

On penalties, the government intends to press ahead with a tougher regime for tax avoiders. This will extend to "enablers" of schemes and negate the defence of "reasonable care" if advice has been taken only from a non-independent adviser. The impact of this new regime will affect a broad range of taxes.

Solid performance from Philip Hammond from a tax perspective. There were no signs of overt UK tax competition in the Autumn Statement (Theresa May kept that for herself earlier in the week). Indeed, it is arguable that by sticking to the business tax roadmap, effective corporation tax increases are around the corner, with the changes to the corporation tax loss regime and restrictions on interest deductibility. The disliked apprenticeship levy looks here to stay and is also a significant revenue raiser for the Government. A potentially significant change – especially for overseas corporate investors in UK land – is the proposed consultation on bringing all non-resident companies within the scope of corporation tax on UK taxable income. The promised land of a simpler tax system looks as far as away as ever, unfortunately.

The Statement confirmed that the Government's intention to introduce major changes to the taxation of resident non-domiciled individuals and UK residential property holding structures. From April 2017, non-domiciled individuals will be deemed UK-domiciled for tax purposes if they have been UK resident for 15 of the past 20 years, or if they were born in the UK with a UK domicile of origin. Also, from this date, inheritance tax will be charged on UK residential property when it is held indirectly by a non-domiciled individual through an offshore structure, such as a company or trust. Although this will close a perceived 'loophole' that has been used by non-domiciled individuals to avoid paying inheritance tax on their UK residential property, these reforms are likely to drive many non-domiciled individuals away from the UK altogether which cannot be in the national interest.

The Government will extend the scope of changes announced in Budget 2016 to tackle the use of disguised remuneration avoidance schemes by employers/employees to the self-employed. Although the final details are awaited, what is of concern is the prospect that the changes will be retrospective and lead to an increased tax liability for a large number of taxpayers who carried out certain tax planning transactions many years ago.

The Government intends to introduce a new penalty for any person who has "enabled" another person or business to use a tax avoidance arrangement that is later defeated by HMRC. Although the legislation is yet to be published, its potential scope has already lead to serious concerns being raised by a number of professional bodies as these proposals could affect the likes of lawyers, accountants and financial advisors who will have the unenviable task of having to ensure that they satisfy their professional duty owed to their clients and at the same time not fall foul of the proposed legislation which will provide for substantial penalties to be imposed on those who 'enable' tax avoidance.

I note that there seems little change in the direction of tax policy – a few reliefs scrapped, a certain amount of tidying up, a stealth tax rise in IPT (again!), corporation tax heading down as planned but no further, nothing helpful to encourage investment like a capital allowance boost or tax incentives for equity. And no sign of radical tax reform now or later with this Chancellor, which may be a reflection of the uncertain times we are in rather than an indication of his natural inclination.

The promised consultation on corporation tax for non resident companies without a permanent establishment will be interesting and makes sense as a relatively neat way of bringing restrictions on interest deduction in for current income tax payers, and avoids what will in future be differential tax rates on income for resident and non resident companies e.g. as property investors. We trust non resident gains are not in his sights!

I am also excited that despite the shadow of Brexit it seems we will eventually see some proposals for the expansion of VAT grouping after the recent CJEU case of Larentia+Minerva, and others.

Currently, generally only non-resident companies with a UK permanent establishment pay UK corporation tax. In this context, the innocent sounding announcement that the Government will consult on proposals to bring all non-resident companies receiving taxable income from the UK into the corporation tax regime is deceptively innocuous. The thinking behind the announcement appears to be to ensure that all companies are subject to the rules which apply generally for the purposes of corporation tax, including the limitation of corporate interest expense deductibility and loss relief rules which are due to be introduced from April 2017. However, although it will affect all companies trading in the UK without a permanent establishment, this measure is particularly likely to adversely change the tax treatment of non-resident companies investing in UK property and continues the recent trend of measures designed to ensure foreign investors pay UK tax in full on UK property. A logical extension of applying UK corporation tax to non-residents would be to tax capital gains of non-resident corporate landlords holding commercial property.

In tax terms, there is not too much to report. The Chancellor's abandonment of previous deficit reduction commitments gives some breathing room, but this is in large part offset by downward revisions to the growth predictions (which are to treated with even more scepticism than usual, following Brexit). This has left little room for the Chancellor to manoeuvre, and those measures introduced (the 2% IPT increase being a prominent example) mostly raise revenue. Of the announcements made, the proposal to consult on bringing non-UK resident companies receiving UK income within the corporation tax regime looks interesting.

It remains to be seen whether moving from a Spring Budget/Autumn Statement to a Spring Statement/Autumn Budget will create the promised efficiency!

There weren't many surprises in this last Autumn Statement for businesses, which will come as a relief for companies many of which are already grappling with the wide ranging and imminent changes to interest deductibility, loss relief and hybrids, despite the fact that a lot of detail is not yet known. Confirmation that the SSE will be simplified is good news.

Ensuring that non-residents are not unfairly advantaged has been a theme in recent statements. Diverted profits tax was announced back in 2014; in the March 2016 Budget we saw the Government addressing non-resident traders and developers in UK property; and in this Autumn Statement the Government announced that it is considering bringing non-resident companies' UK income within the corporation tax regime. This would presumably give them the benefit of the reducing corporation tax rate as it diverges from the 20% income tax rate, but at the expense of being subject to the numerous old and new corporation tax rules limiting (for example) interest deductibility and loss relief.

Oil and gas companies will not be surprised that there were not many announcements targeted at that industry after the rate reductions and incentives that have been announced over the last couple of years. Some may be disappointed that the Government has not seized the opportunity to implement more radical reform, such as transferable tax credits to mobilise late life asset transfers or exploration incentives. However, the Chancellor has reassured the industry that the "Driving Investment" plan has not been forgotten and so we can hopefully expect some of these ideas to be announced in March, if not before.

We can expect HMRC to remain aggressive in the tax controversy arena. The Autumn Statement pursues the ongoing theme of countering tax avoidance with a renewed focus on the introduction of penalties for taxpayers using avoidance schemes which are challenged but defeated as well as for enablers of those schemes. Significantly there is also a renewed appetite to litigate cases which is expected to bring forward £450 million in revenues.

Probably the most important aspect of the Autumn Statement was that this would be the Chancellor's last (and first) Autumn Statement. It was announced that, from 2017, budgets will be delivered in the autumn. The OBR will produce a forecast in Spring 2018 and the Government then will make a Spring Statement responding to that forecast. The launching of consultations will be by means of the Spring Statement. It is considered by the Government that this will improve external and Parliamentary scrutiny of proposed tax measures. That is a good thing. Particularly in the light of the current political dysphoria that has, and will, occasion, concomitantly, fiscal turmoil.

On the avoidance front, measures that will be introduced include (as presaged in the 2016 Budget) a fixed rate penalty of 30% for participating in VAT fraud, which will be exigible on businesses and company officers who "knew or should have known that their transactions were connected with VAT fraud." HMRC consider that there is a misalignment between this "knowledge principle" and the civil penalty regime's tests of "deliberate" or "careless" behaviour; and that that can require separate Tribunal hearings. Whether this additional stick is, indeed, necessary, and, a fortiori, necessary as regards company officers, is moot.

The Chancellor should be congratulated for largely resisting the temptation to tinker with the tax legislation. Indeed, his key message was an express recommitment to existing tax policies. This was a reassuring approach for our uncertain times.

One exception was the abolition of ESS. Even there, however, I welcome that he has allowed the tax benefits to remain for existing arrangements – unlike, for example, when the income-based carried interest rules were introduced. The abolition of ESS shows that the arrangements were still being exploited for the benefit of highly paid employees despite the introduction earlier this year of a £100,000 individual lifetime limit.

One thread that connects a number of the proposed changes and consultations is the elimination of differences in treatment of taxpayers or receipts to remove arbitrage and therefore potential tax avoidance . Obvious examples are the removal of benefit in kind treatment for all but a handful of salary sacrifice arrangements, and the consultation to bring non-UK resident companies in receipt of taxable income into the charge to corporation tax. This is a welcome approach. One would hope it will mean a review of the tax system as a whole rather than specific changes to this provision or that to eliminate a particular identified avoidance arrangement. That approach has caused the tax code to become unwieldly.

Another interesting measure is the requirement for taxpayers to obtain independent tax advice to prevent the application of penalties. This will, indirectly, help prevent promoters of tax schemes lure unsuspecting taxpayers into so called "tax efficient investment structures" with the potential disastrous results if the scheme is successfully challenged. The imposition of tax related penalties on advisers who facilitate tax avoidance is problematical as it will affect the independence of lawyers and be a retrospective penal provision in its operation as the outcome of a so called avoidance case is not always predictable as the UBS restricted securities case showed: the judges in the Upper Tribunal and the Court of Appeal found for the taxpayer but those in the First-tier Tribunal and the Supreme Court found for HMRC.

While the Chancellor provided little certainty on how Brexit might affect us all (save that we have a lot more debt), the message on tax was that there are to be no surprises: nothing to see here; move along. Corporate tax policy proceeds as planned, and corporation tax rates will reduce as forecast. All this was welcome. By the same token, changes to interest deductibility and use of losses are also in the offing. There will be lots of detail for businesses to get used to here but it is not unexpected. Changes to the substantial shareholdings exemption have been heavily discussed in recent months and it is good to see that some concerns appear to have been taken on board. Of more concern was the passing suggestion of making offshore companies with UK income subject to corporation tax. This could be a major change for some sectors and needs careful handling. But the general theme of no surprises/no shocks is itself the best way to attract business into the UK – more of the same, please!

There was very little in the Autumn Statement relating to HNW individuals other than a statement that the changes to inheritance tax on UK residential property and the new deemed domicile regime will be introduced from April 2017, dashing any remaining hopes of a Brexit related postponement. The proposed protection for settlements established prior to an individual becoming deemed domicile appears to have survived the two consultations but we will have to wait for the draft legislation (due 5 December) for confirmation of how this will work. We also saw confirmation that the Government would (slightly) liberalise the personal portfolio bond regime and taxation of part surrenders of insurance policies but both had been heralded in the Budget and subsequent consultations and yesterday's announcement did not add any useful detail.

PLC's coverage of the Employee Shareholder Regime has always identified the risk that the continued existence of that regime and its associated tax advantages might be curtailed by the Government and most practitioners have been anticipating this. Whilst its withdrawal is therefore not unexpected, the related consequence of no longer having the ability to agree the market value of shares acquired by employees with HMRC before those shares are acquired, is likely to be sorely missed by employees and their employers.

The Government's announcement of plans to introduce penalties for those practitioners who advise on the use of tax arrangements which are ultimately defeated by HMRC as being tax avoidance arrangements, is welcomed but will inevitably create uncertainty and trepidation for all tax practitioners. Tax is complicated and practitioners may honestly not know at the time that an arrangement is put in place whether it is, or might be, capable of being successfully challenged by HMRC in years to come, perhaps under new legislation. Although there are no details yet of the nature of the penalties or their scope, it is hoped that such scope will be tightly drawn so that only promoters of genuine tax avoidance arrangements are targeted.

In an uncertain post-Brexit referendum world of higher borrowing and lower growth, you might have expected the Chancellor to cling to a few old certainties.

The Government's renewed commitment to the main corporation tax elements of the Business Tax Roadmap – interest relief restrictions, group losses and hybrids – on the same timetable is, however, far from a recipe for certainty. The confirmation that all of these regimes will take effect next year, whilst predictable, guarantees a period of further change and turbulence in the corporate tax world. The introduction of any one of these regimes is a significant reform. There is a real risk that their almost simultaneous introduction could herald a period of amendments in successive Finance Bills similar to that which followed the introduction of the debt cap in 2009. The Chancellor has passed up the opportunity to pursue a more measured timetable of reform which his relaxation of the timetable for the elimination of the budget deficit provided. That he has done so is all the more surprising given the increased focus on the competitiveness of the UK tax regime that Brexit threatens to bring.

There are a few crumbs of comfort. The proposal to introduce secondary transfer pricing adjustments, whilst not completely abandoned, seems to have been pushed further down the track and the proposals to remove the investing company requirement from the substantial shareholding exemption promises a simpler more competitive regime.

It is a mixed bag for investment into the UK. The relaxation of the substantial shareholding rules is welcome and will encourage investment. Bringing non-resident corporate landlords into the UK corporation tax charge on income is likely to be less welcome.

Some of the changes related to employment taxes were widely trailed, but are disappointing nonetheless (apart from the tax relief in respect of legal support provided to employees, which is a relatively minor point in the wider scheme of things). For instance, the changes in relation to salary sacrifice, where tax relief is being removed save in respect of pensions, childcare, cycle-to-work and ultra low emission cars. It is a shame there will be no tax support for gym membership and health checks. Gym membership and health checks should be encouraged.

Less widely trailed was the abolition of the tax reliefs associated with Employee Shareholder Shares. Why not amend the qualifying conditions for the relief – or put income limits around those who can qualify - rather than abolish the relief altogether? Whilst described as a response to tax planning, it has the feel of a tacit acceptance that the relief was not properly designed/targeted in the first place.

The Chancellor has announced his intention to bring corporate non-resident landlords within the rules for corporation tax. As well as the anti-hybrid regime, these include the restrictions on interest deductibility and loss relief that Hammond confirmed he would implement in April 2017, in line with the timetable proposed by his predecessor. In many ways this should put the income of such non-resident companies on a level playing field with their domestic counterparts from a taxation perspective.

It is disappointing for large businesses that the measures on losses and interest deductibility were not postponed, or scrapped altogether in the case of the new loss regime, particularly given that the UK is looking like an uncertain destination for investment following the Brexit vote. On the positive side for business, Hammond confirmed his commitment to the Business Tax Road Map which includes a commitment to lower the rate of corporation tax to 17%. This measure should see most companies pay less corporation tax overall despite the base broadening measures that will also be introduced.

The Chancellor's confirmation that he is recommitting to the Business Tax Road Map published in March by his predecessor was very welcome and will help to provide a degree of certainty in uncertain times that businesses need to make their long-term investments. In particular, the pledge to cut the rate of corporation tax to 17% by April 2020 seems sensible, with any loss of corporation tax revenues likely to be offset by resulting retained levels of UK activity and employment taxes. Given the Brexit vote, it seems counter-intuitive for the Government to be pressing ahead with planned reforms to non-domiciled tax status which will see certain non-domiciled individuals deemed domiciled in the UK from April 2017.

The Government announced it is considering bringing non UK resident companies UK income into the corporation tax regime. This would represent a major change, with potentially far reaching implications, for example the application of corporation tax rules on deductions for interest and loss relief and whether this would include not just trading income but interest, royalties or possibly chargeable gains.

Relaxation of the investor conditions relating to the substantial shareholders exemption (SSE) were expected, making SSE available to a wider category of investor. Although the detail is not yet available, this is very welcome increasing the UK`s attractiveness as a holding company jurisdiction.

Despite hopes that the Chancellor would remove the additional rate of SDLT (3%) for certain categories of institutional or large scale investor in residential property, there was no change to SDLT rates. The Government instead focused on other ways of supporting house building, so it remains to be seen whether the continued application of the additional SDLT charge affects investment in build to rent housing.

In order to make a success of the post-EU referendum economy it was vital for the Chancellor to send out a clear signal in the Autumn Statement that the UK remains the right place for multinational companies to make investments.

One way to achieve this will be to take forward the proposal to simplify the Substantial Shareholdings Exemption, which was confirmed by the Chancellor and will take effect from April 2017. If the Chancellor could also simplify the dividend exemption for large companies, this would mean the UK has a participation exemption comparable with those of other tax benign jurisdictions and so would make the UK an even more attractive holding company jurisdiction.

The Chancellor will, however, also have to pull off a delicate balancing act to ensure that any changes to UK domestic rules which encourage in-bound investment take account of public sentiment. The UK's international commitments under the BEPS Project have until now had the full backing of the UK Government. It seems unlikely that the Chancellor would scrap proposals covered in the existing BEPS consultations, particularly as changes to the interest deductibility rules were confirmed in the Autumn Statement, but it is possible that the introduction of other measures may be delayed and/or grandfathering rules could be introduced.

Speculation had been rife in the lead-up to this year's Autumn Statement about what the Chancellor might be prepared to do with his international tax policies to increase UK competitiveness. The short answer appears to be: not very much.

The Chancellor's confirmation that he would stick to the Business Tax Roadmap means that the announced corporation tax rate decreases proceed merely as planned: no acceleration of the cuts and no additional cuts announced so far. It means that the UK interest barrier is proceeding and, contrary to the UK's stated position in the context of the BEPS Actions, will not carve out banks and insurance companies. It means that the anti-hybrid measures – with "minor" changes yet to be published – and the changes to corporation tax loss relief will also proceed. Multinationals hoping for any meaningful relaxation of these pre-23 June policies will have been disappointed, though the proposed relaxation of the SSE eligibility tests are welcome.

The Chancellor also announced that, in principle, tax policy changes would now be a once-yearly event at an Autumn Budget. The hope is that this will contribute to certainty and confidence in the process although there is as always enough wiggle-room for special measures to be introduced. However, measures that could increase uncertainty for a time include a consultation on the extension of corporation tax to non-resident companies and clarifications to partnership taxation.

Finally, the projected receipts data for diverted profits tax suggest that DPT will yield less than £50 million in aggregate in 2021/2022. The Chancellor will doubtless wish to consider whether this a sign that DPT will have succeeded in changing behaviour or is an unnecessarily and disproportionately complex product relative to the expected yield to HM Treasury.

One legacy of George Osborne proved to be short lived with the abolition of tax reliefs for employee shareholder shares. Existing arrangements will be unaffected and employees who have been offered shares and received independent advice before 1.30 pm on 23 November can still qualify (providing the shares are issued in time). The abolition will leave many companies with no qualifying employee share plan. Many of these companies used shares for rights to reward management for genuine commercial growth (rather than for abusive reasons) and are now likely to use "growth share" arrangements as the next best alternative.

One welcome announcement, however, was the simplification to the proposed new rules on the taxation of termination payments (which are set to come into force on 5 April 2018). In assessing what an employee would have been paid during their notice period had the termination not occurred (and hence what will be fully subject to PAYE and NIC) it will now only be necessary to count basic pay during the notice period. The previous proposals involved including "expected" commission and bonuses and would have left considerable scope for dispute - payments in lieu of these items will presumably now count towards the £30,000 tax free limit.

Few rabbits. A smaller hat. And very, very little detail. Practitioners will be awaiting further news on many of the matters briefly announced – waiting eagerly in the case of SSE reform, and nervously when it comes to enabler penalties. Swift clarification would be particularly welcome that next year's consultation, on extending corporation tax for non-resident companies, will be about the relatively narrow class of companies currently within the direct charge to income tax on UK source income.

Abolishing the "investing requirement" of the substantial shareholding exemption (SSE) is obviously a positive step, and finally removes a major (and entirely needless) obstacle to making the UK's holding company regime fully competitive with other leading holding company jurisdictions. Unfortunately, the uncertainty surrounding Brexit and, in this context, issues such as the future applicability of the EU Parent-Subsidiary and Interest and Royalties Directives, cast a new political and legal shadow over the attractiveness of the UK as a holding company jurisdiction – certainly until the effects of Brexit (including the continued status of EU withholding tax and other legislation) are known. Nonetheless, the revision of the SSE is to be welcomed and will undoubtedly help with many holding and investment structures.

Few surprises in a rather lacklustre speech from our new Chancellor of the Exchequer in his first – and last – Autumn Statement. The next Spring Budget will also be his last, but never fear, we will have a second Budget in the autumn next year, followed by a Spring Statement in 2018.

Perhaps this "new" pattern (echoing Ken Clarke from 20 years ago) will allow more effective Parliamentary scrutiny of Finance Bills, preventing the continual amendments that have plagued some tax areas, such as the loan relationship rules. Taxpayers will welcome the Finance Bill being enacted before the start of the tax year, avoiding the ludicrous situation of the Finance Act 2016 receiving Royal Assent in September, almost half way through the tax year, with some measures retroactive back nine months.

The also UK continues its eager implementation of the OECD's BEPS proposals, next being the proposed restriction on the deductibility of corporate debt costs to 30 per cent of adjusted EBITDA. It may be too much to expect us to get these rules right first time: amendments are already needed to this year's BEPS-inspired anti-hybrid rules to ensure the legislation works as expected (for which read, the original legislation was introduced too quickly and is flawed). Next up, perhaps some news on the multilateral instrument.

The proof of the pudding will be in the eating: draft clauses for a number of measures – most announced in the past by George Osborne, to be included in the Finance Bill 2017 – will be published on Monday 5 December."

The tone of this year's Autumn Statement was notably downbeat in light of weaker than expected tax revenues (particularly in the context of income tax) and concerns around future economic growth in the post-Brexit environment. It was unfortunately clear that any available jam would be spread thinly today, with no real certainty on whether much jam would be available tomorrow. In light of this it was unsurprising that the headline business tax announcements broadly followed on from previous consultations and there was once again a focus on anti-avoidance measures such as the closing down of ESS planning, coupled with the familiar soundbite that taxpayers should "pay their fair share". It is to be hoped that the government does not go too far in terms of viewing standard transactions through an anti-avoidance lens, especially given the complexity of tax legislation and the indication that the government is keen for HMRC to litigate more. In particular, the focus on intermediaries who arrange "complex structures for clients holding money offshore" and proposed consultation on extending corporation tax to non-resident companies hints that structures with a cross-border element are currently viewed with a general air of suspicion by the authorities.

The Chancellor announced a reduction in the money purchase annual allowance to £4,000 from its present level of £10,000 from April 2017. This may help to reduce the possibility of savers recycling their pension savings to 'double recover' on pensions tax relief. However it represents a further change to the pensions tax system, and a reduction in tax relieved pension allowances, which cannot be said to be a step designed to encourage pension saving. I welcome the Chancellor's decision to exempt pension arrangements from the announced changes to salary sacrifice, providing for continued stability in this area for the many schemes that use this facility.

I also strongly welcome the announced consultation on options to tackle pensions scams and to ban cold calling relating to pensions. Pension scams are a serious issue and we have encountered situations where this has affected scheme members in practice, with potentially devastating financial results. The budget statement mentions that this consultation will consider giving firms greater powers to block suspicious transfers – I await the detail on this; again in practice this is a very difficult area for pension trustees who are faced with members wishing to transfer their benefits, and further clarity on what trustees can do in these circumstances would be welcome.

The most interesting amongst the latter, in my view, is the "clarification of tax treatment for partnerships". All we know, so far, is that there will be legislation "to clarify and improve certain aspects of partnership taxation to ensure profit allocations to partners are fairly calculated for tax purposes." This type of issue was one of the main themes of the consultation document earlier this year on partnership taxation. HMRC seemed only concerned with ensuring that the right partners paid the right tax at the right time, and how to deal with inconsistencies between, for example, persons listed as partners at Companies House and those shown as partners on the accounts or partnership returns.

What was completely missing from the consultation document, and from today's announcements, is any suggestion that the Government might deal with the inherent unfairness in the compliance rules for partnerships. The particular problem is that partnerships are required to have a nominated partner who is the person required to submit an annual partnership return to HMRC. That return includes a list of the partners and their profit allocations and those are the amounts that each individual partner must put on their own tax returns. The nominated partner is also the only person who is entitled to, for example, amend the return or appeal HMRC decisions.

What this means, of course, is that if individual members of the partnership dispute the figures on the tax return, they have no standing to amend the partnership return or, indeed, to force the nominated partner to do so. So, for example, a partner who disputes their profit share as shown on the partnership return is required by these rules to put what they believe to be an incorrect number onto their personal tax return. But their personal tax return must be signed by them as being complete and correct to their best of their knowledge and belief, so there is a clear dichotomy here.

Philip Hammond's first Autumn Statement as Chancellor of the Exchequer comes at a momentous time for the government. The first major fiscal event following the vote to leave the EU was a much anticipated occasion, but in terms of tax, the announcements were relatively low key, many simply confirming the government's commitment to previously announced measures.

On the whole, the Chancellor seems to have taken a pragmatic 'watch and wait' approach to the uncertainty presented by Brexit. Although there were no obvious specific tax announcements made in reaction to Brexit, several measures, including confirmation of the reduction in headline tax rates and some relaxation of the circumstances in which non-doms can remit income to the UK without triggering UK tax charges, may offer some insight into the fine balance which the Chancellor is attempting to strike.

New announcements of significant note were thin on the ground, but an absence of yet more change must be considered a good thing. A period in which the Chancellor refrains from tinkering with the tax code and desists from overburdening businesses which are still trying to get to grips with the second longest Finance Act in history is to be applauded. And it seems as though the Chancellor has taken this opportunity to slow down the pace of change and introduce a period of rationalisation and stability for businesses one step further by making this not only his first, but also his last, Autumn Statement. It is hoped that this will, in future, limit the number of tax changes we can expect to see on an annual basis.

Employee shareholder status (ESS) did have the incidental benefit of raising awareness of the Nuttall Review's alternative vision of employee ownership (EO). Opponents of ESS (and that meant pretty much everyone) readily stated their support for EO in contrast to a measure that no-one ever thought would improve labour market flexibility and which from the outset was identified as a tax planning idea. The Institute for Fiscal Studies described ESS as a "billion-pound lollipop" for tax avoiders. So it is actually no surprise at all that the Government's reason for withdrawing ESS is that it is used for tax planning rather than supporting a more flexible workforce. The Government's response in December 2012 to the consultation on ESS stated clearly that only a very small number of the 209 respondents welcomed the scheme. ESS was a headline grabbing measure for the then Chancellor of the Exchequer, George Osborne. It is a shame that all the resources expended on ESS were not channeled into promoting wider employee share ownership and EO and the budget used instead to index the allowances under tax advantaged share plans and for qualifying bonus payments made by a company controlled by an employee-ownership trust (EOT). (ESS tax reliefs go for shares acquired from 1 December 2016. There is no change to the EOT tax reliefs introduced as a result of the Nuttall Review.)

Disguised remuneration remains the Government's go-to measure of choice in dealing with employment tax planning. The Autumn Statement included further measures in this already heavily legislated context, including the announcement that employers will be denied tax relief for an employer's contributions to disguised remuneration schemes, unless tax and NICs are paid within a specified period, in order to deter them from using such schemes. Moreover, the Government also announced that it would also extend the disguised remuneration schemes by the self-employed. The proposal on self-employed persons is new and will be interesting to see the scope of these proposals in the light of recent changes such as the disguised investment management fee rules.

'Employee shareholder shares' was a good example of a policy developed 'on the hoof' which, as responses to the original consultation foresaw, fell far short of achieving the aim of enabling a broad range of employees to benefit from the growth in value to which they contribute. Sacrificing valuable employment rights was too high a price for most employees to pay for the opportunity to benefit and, in practice, given the CGT annual exempt amounts, it is only the higher paid who benefit. Allowing the acquisition of 'growth' shares in a controlled subsidiary inevitably meant that the scheme was primarily of attraction to management teams in private equity-backed companies – not the broader range of employees for whom it was intended. Its withdrawal is no surprise.

The Autumn Statement was unexciting as had been suspected. The interest is really in the detail that is promised on the BEPS-related, EBITDA-linked interest cap rules and the carry forward loss restriction and changes to the group relief rules which promise to be long and detailed. On the more positive side it can be hoped that the Government succeeds with its policy of making the UK a more attractive holding company location with the promised modernisation of the substantial shareholding exemption and, of course, we have finally seen the final end to the much discussed employee shareholder tax break. The private funds industry is also waiting to see what comes out of the consultation on partnership tax reform and hopes that HMRC can be persuaded to properly distinguish between trading and investment partnerships and do not place excessive and unworkable compliance and reporting obligations on investment partnerships.

The Chancellor's "simplification" of the Budget process and commitment for example to the Business Tax Roadmap is to be welcomed. On a day however when BDO and others following separate surveys have reported that businesses and others consider the UK's tax system to be not fit for purpose and/or would otherwise swap higher rates of taxation for simplification, it is disappointing to see to a large extent simply more tinkering: abolition of previous incentives/reliefs (employee share status), further tweaking of existing reliefs (loss relief), more penalties in the shape of a new penalty for those who 'enable avoidance' and consultation on more rules and regulations for advisors e.g. requirement for them to register clients who hold money offshore, along with details of the relevant structure(s). Whilst these measures address some of the issues in our tax system, they do not demonstrate that the government is serious about simplification and ultimately tackling the root cause of avoidance i.e. the complexity of the tax system itself.

So, it was Philip Hammond's first and last Autumn Statement, and what can I say? No, seriously, what can I say? There was little new on the corporate tax front, which is not necessarily a bad thing.

The Chancellor will move to a "single major fiscal event" each year, although there will be two Budgets next year as a last hurrah. This move should improve scrutiny and reduce the need for tax change for tax change's sake and is welcome.

The Government recommitted to the business tax road map and, sadly, but predictably, is pressing ahead with the corporate interest expense restriction and reform of loss relief, including their April 2017 timetable.

Changes to the substantial shareholding exemption will be more welcome, including, it would seem, removing the trading requirement for investing (as opposed to investee) companies, which should allow institutional investors to benefit more easily and SSE to apply straightforwardly on the sale of a holding company's last trading subsidiary.

There were fewer stings in the tail than in recent years, although the government will consult next year on bringing all non-resident companies receiving taxable income from the UK into the charge to corporation tax. What does that mean?!

So, it was a calmer Statement, delivered by a calmer Chancellor. It is apt, perhaps, that the biggest tax change in revenue terms was in the increase of insurance premium tax by 2%. Next year promises more; given the OBR forecasts on Brexit and the expected increase in US interest rates, the Chancellor will surely be guaranteed his "major fiscal event"….

In his first and soon to be last Autumn Statement, the Chancellor managed to defer the now thorny topic of MTD. The only announcement was that a consultation response is to be published in January 2017. This will need to be robust and hopefully include some reassurances and concessions to address the many concerns raised by taxpayers and the professional tax and accounting institutes about these changes.

Whilst we are all generally 'pro digital' we are also concerned about a strict rather than flexible timetable to 2020. We are also keen to see how MTD can assist rather than hamper business and individual taxpayers to keep the economy moving. At the moment there are more questions than answers.

Is that really all there is? My initial reaction was to refresh the relevant page of the Treasury website several times just to make sure nothing more had been published, but in the end there really is very little for us to talk about; though those of us who have criticised previous Chancellors for constant tinkering with the tax system can hardly criticise Philip Hammond for leaving us short of material on this occasion, nor for seeking to adopt a more stable and considered approach to tax policymaking.

What is more, the few genuinely new changes that have been announced appear very sensible. The apparent removal from the substantial shareholding exemption of the requirement for the investing company to be a trading company is a welcome simplification, as this condition is frequently impossible to apply to large multinational groups with any degree of certainty or precision. And I will shed no tears for the passing of employee shareholder status, abolished only three years after it was created after having become, entirely foreseeably, a vehicle for avoidance.

The loss of the Spring Budget is somewhat unexpected - if anything it would have seemed more likely for the fiscal aspects of the Autumn Statement to be axed.

The announced changes to the substantial shareholding exemption are very welcome - in particular the abolition of the investing requirement which was a frustrating limitation to the relief. The benefit to businesses of the proposed comprehensive exemption for companies owned by qualifying institutional investors cannot be assessed until we see the draft legislation, but it sounds promising.

As expected, the government is going ahead with the restrictions on interest deductibility. Perhaps more surprising is the conclusion that banks and financial institutions should fall within the general rules, particularly in the case of net interest recipients. The door is left open for protection to be added later as this area will be kept under review and government discussions with the OECD on the rules are ongoing.

Overall, the Autumn Statement appears relatively low key for businesses but the draft legislation, when we see it on 5 December, may yet produce some surprises.

With the emphasis on the Autumn Statement on infrastructure spending, and no appetite for increases in general taxation, it was no surprise that the Chancellor focussed on avoidance measures, including BEPS related changes, to raise revenues. However, in the wake of the Brexit vote and continuing economic uncertainty, it was extremely disappointing that the Chancellor has rejected the widespread calls to at least delay the introduction of the interest restriction measures. The Government's zeal to introduce these measures ahead of many competitor jurisdictions appears misplaced and their hasty introduction is likely to create problems for businesses. It was equally surprising that the Government also announced that banking and insurance groups will be subject to the rules in the same way as groups in other industry sectors, given the obvious concerns over the application of the rules in the context of net receivers of interest. On a positive note, and in keeping with the Autumn Statement theme, the Government will at least widen the provisions proposed to protect investment in public benefit infrastructure.

Recognition that, for the UK to work as an ISPV jurisdiction, it needs to provide tax exemption for ISPVs is very welcome. Other ISPV jurisdictions, such as Bermuda do not tax profits of ISPVs or apply any withholding taxes on their payments to investors, and so exempting UK ISPVs authorised by the PRA and FCA from UK corporation tax on their risk transformation activities and from withholding taxes on their payments to debt or equity investors is a sensible and pragmatic approach. However, whilst it is unsurprising that the UK Government is very keen to ensure that UK ISPVs cannot be abused for tax avoidance, some of the suggested measures appear to go unnecessarily far. For example, the current draft tax regulations would disqualify ISPVs from UK tax exemption in the event of corporation tax compliance failures such as delays or errors in filing tax returns. This seems particularly draconian considering that many of the anti-avoidance provisions (including this one) trigger permanent loss of ISPV tax exemptions even if the failure is subsequently rectified. It can only be hoped that this measure is dropped or watered down following the consultation exercise.

As announced at Budget 2016 and following consultation, the government will amend the definition of a taxable disposal for Landfill Tax purposes in Finance Bill 2017. The aim of this measure is to bring greater clarity and certainty for taxpayers on the Landfill Tax liability of activities carried out at a landfill site. It is envisaged that it will come into effect after Royal Assent of Finance Bill 2017, on a day to be appointed by Treasury Order.

The background to these changes was discussed at a landfill tax round table hosted by HMRC on 30th September 2016 to discuss the industry responses to the recent consultation "Landfill Tax: improving clarity and certainty for taxpayers" and their plans for the future of the tax.

The general aim of the proposed changes is to simplify the tax by bringing nearly everything that is put into a landfill cell within the scope of the tax. This is partly in response to the large number of landfill tax refund claims submitted by operators in respect of material used for site engineering purposes. It is proposed that anything outside of the cell area would not be taxable. The cell would be defined as the void space above and underneath the liner. It is envisaged that these changes would mean that there would be no further need for the Landfill Tax (Prescribed Landfill Site Activities) 2009.

It is proposed that the existing list of exemptions would remain unchanged as would the water discounting rules. HMRC also confirm that there are no plans to change the waste streams that are currently treated as being liable to the lower rate of landfill tax. This was due to a lack of internal resources.

Some concerns were raised by the attendees over the use of shredded tyres in the drainage layer which could be liable to tax if only a reference to "granular material" is used in the proposed legislation. Also, in order to reduce the administrative burden on site operators, HMRC propose that the information area and restoration material notification schemes are discontinued. However, what became apparent was that HMRC did not realise that these areas are sometimes situated within the cell. This could mean that material intended for recycling or restoration would inadvertently be liable to landfill tax if it is stored in the cell. HMRC have agreed to review these areas.

There are a few obvious positives:

Unfortunately, these will be more than offset by the pain yet to come. Sadly, no delay to the interest barrier (and the same rules to apply for banks and insurance companies?) and loss carry forward to be restricted as previously suggested; and only tinkering with the horrid hybrid rules in effect from 1 January. Real concerns remain as to how much the government has really listened to the strong and consistent rejection of the original form of the enablers penalty regime: anyone else expecting a lump of coal in that particular stocking?

The taxation of UK real estate has perhaps been subject to more change in the last 5 years than any other area of tax. In continuing this trend, the Government has announced a consultation next year on bringing non-UK resident companies that receive UK taxable income into the corporation tax regime. If this change is implemented, it would be a major change to the way non-UK resident corporate landlords are taxed and would bring them within the scope of UK corporation tax rather than being subject to UK income tax as is currently the case. It would also ensure that non-UK resident corporate landlords are subject to the same limitations in respect of interest expense deductibility as UK resident corporate landlords. This would also presumably equalise the rate of tax on rental income given that non-UK resident corporate landlords will be subject to a 19% corporation tax rate from April 2017 whereas a non-UK resident corporate landlord is currently subject to 20% income tax on net rental profits. It remains to be seen whether the Government will then seek to ensure gains arising to non-UK resident corporate landlords on a disposal of UK commercial property are subject to UK corporation tax to really level the playing field in the taxation of UK real estate.

Share plan practitioners' only direct point of interest in yesterday’s statement is the abolition of the employee shareholder shares tax break. ESS came as a surprise when it was introduced and its continuation for so long (and the extent to which HMRC appears to have been happy to give extremely generous interpretations of legislation, for example, to use existing shares and give valuations in advance) has also been a surprise, when there has very little intended use of the scheme for long-term employee ownership. It has instead more been used (perfectly legitimately) for executive arrangements in private companies as a wrapper for growth shares. The cap on tax-free gains at £100,000 introduced in the March Budget for share awards after that date was an early sign of how it had become regarded very sceptically in the Treasury and being a pet project of George Osborne may also not have helped delay the final blow. This should also free up some SAV time and resources! Thankfully for those who have used the scheme, the tax-free sale treatment of ESS shares already awarded is being preserved, although even this cannot be guaranteed. The sudden withdrawal of taper relief (in favour of entrepreneurs' relief) in 2008 is a reminder of what can happen here and a reminder generally that no tax rate or arrangement is indefinite. Other tax favoured share plans are left unamended though, and share plan practitioners will be glad that the proposal appears to have been dropped to include bonuses and share vestings/option gains which might occur in a notice period as being part taxed as a taxable termination payment when an employee leaves, and these will now just be taxed under normal employee share tax rules. Draft legislation comes on 5 December and there it will also be interesting to see the salary sacrifice legislation, hoping that is does not cause complications for bonus deferral into shares or bonus deferral generally, where there is no ultimate NIC or income tax saving but the timing of any tax charge is clearly important.

A slightly flat Autumn Statement – although the insurance industry will be stunned by yet another increase in IPT – inevitably some or all of the cost will have to be passed onto business, and IPT planning may start to come up the agenda…

Focussing on the positives, two actual or potential simplification measures that could have a significant impact for the corporate tax practitioner are those relating to the SSE and stamp duty on shares.

With regard to the SSE, we don't have many details as yet, other than a change to remove the investing requirement and the provision of a more comprehensive exemption for companies owned by qualifying institutional exemptions (presumably including investors like pension funds). Although not as favourable as a wholesale removal of all trading-based conditions, the removal of investing requirements will be of significant benefit in many cases.

The scope of the potential stamp duty simplification is unclear, but there are myriad ways in which this outdated and unwieldy regime can be simplified. Might abolition also be contemplated?

On the less positive side, it is disappointing that the commencement of the rules on tax deductibility of corporate interest expense and reform of loss relief are still scheduled to come into effect from April 2017. Apart from the burden this will place on businesses, the complexity of the rules involved is likely to result in a need for immediate amending legislation – as was announced yesterday for the hybrid mismatch rules.

It is very disappointing that there was no decision to defer implementation of the hybrid mismatch legislation - there was hope that this might have been the case. The legislation is extremely complex and difficult to understand and apply. I am not sure for example if the full scope of the imported mismatch provisions and their application to cross border arrangements is understood. HMRC has found it too difficult to even produce guidance on this legislation (the original guidance having been withdrawn in the summer) notwithstanding that the effective date is less than 2 months away. It has also been announced that changes are needed to make sure that the legislation works as intended. Self assessing under the new legislation will be challenging to say the least.

On the bright side, the business community will welcome the proposed amendment to the substantial shareholding exemption, and the infrastructure sector will feel relief (though perhaps short-lived?) that the public benefit exemption to the new 30% of EBITDA interest restriction will be widened. But the bad far outweighs this. Going ahead with the 30% restriction on such a tight timetable, and in light of Brexit, could be described as madness. Add to this the new carried forward loss relief restrictions, the proposal to extend corporation tax to non-resident companies, and the VAT grouping consultation, and Britain may be open for business but query who will come buy when other regimes in Europe are more stable? Advisers won’t be happy to see the registration of offshore structures, either – has HMRC heard of privilege? Even the change to the Budget/Autumn Statement process does not sound like progress – there's to be no significant changes announced in the Spring Statement but "The government will retain the option to make changes to fiscal policy at the Spring Statement if the economic circumstances require it" – oh well, expect a slew of TAARs each Spring, then.

It sounds as if there will be real improvement in the SSE regime and with a bit of luck the government will be dealing with some of the problems in the hybrids legislation, though I fear many will remain. It will also be interesting to see whether anything coherent comes out of the very confused Condoc on partnership taxation.

But paragraphs 4.24 and 4.26 of the Autumn Statement were the main focus for me. The property sector has been waiting anxiously to see whether the new restriction on interest deductibility will recognise that higher leverage is entirely justifiable where the borrowing is secured on property, and whether it will apply at all to companies that pay income tax rather than corporation tax because they are non-resident landlords.

Paragraph 4.24 doesn't have much to offer on the first point, but the widening of "provisions proposed to protect investment in public benefit infrastructure" could conceivably make a real difference. On the second, paragraph 4.26 suggests a radical solution. While rent paid to NRLs is not the only possible type of "taxable income", it is obviously the main target. If such companies are brought into the corporation tax net, they may have to grapple with the new rules (including on carry-forward losses) and also some longstanding ones, such as the non-deductibility of "results-dependent" interest and the unallowable purpose rule. At least the applicable tax rate will then be lower – and, presumably, highly geared NRLs can continue as they are pending the outcome of the consultation.

The UK government continues to use the Real Estate sector as its "go to" source of tax revenue. Following the extension of corporation tax to non-residents trading in UK land in July this year, we now have the proposal to bring non-resident landlords into the charge to corporation tax (rather than income tax) on their UK income profits. This fits with the government's approach of broadening the scope of UK corporation tax to include the profits of non-residents arising from UK land.

At one level it is good news as the non-residents would benefit from the falling corporation tax rates and be able to deduct loan relationship expenses in accordance with their accounting treatment. We might even see the end of the withholding tax regime under the non-resident landlord scheme to be replaced by corporation tax self-assessment rules.

However, on the other hand, there is a clear indication that the government intends that the interest restriction rules (and carry forward of loss relief rules) would apply to non-resident investors in UK land. This is likely to have a significant impact on the measure of UK taxable profits of a non-resident's property business because such businesses are typically heavily leveraged with shareholder debt.

In other words, non-residents would be likely to suffer higher UK tax on their UK property business profits. It feels like it cannot be long before the UK government takes the final step and extends the scope of corporation tax to include capital gains realised by non-UK residents disposing of UK commercial property. That would mark the end of any fiscal incentive for non-residents to invest in UK land.

Further changes to the EIS/VCT regime will be made in Finance Bill 2017. Given the recent upheaval that the regime has been through, further changes could generate a collective sigh of despair. However, whilst we have little detail, it appears that the changes offer some cause for optimism. The announcement of a consultation into options to streamline and prioritise the advance assurance procedure is most welcome – being the major issue facing EIS/VCT investors and putting them at a competitive disadvantage to other investors. It remains to be seen what options will be announced, but whilst the Government committing more resource is probably wishful thinking, hopefully the options would include separating simple and complex applications.

Other changes are clarifying the EIS rules for share conversion rights, following HMRC’s review of this area; enabling VCT regulations to be made to provide greater certainty to VCTs in certain share for share exchanges; and tidying-up the VCT legislation around follow-on funding. At first glance, all look helpful.

The main disappointment is that the replacement capital rules will not be introduced and will be reviewed over the longer term – it sounds like this is being kicked into the long grass!

The Autumn Statement provided for few tax surprises (save for the increase in IPT) but many spending commitments. So we may yet see material tax changes announced in what will be the last Spring budget next year and/or in the new Autumn budget. Time will tell, but what the Chancellor has confirmed is that the various areas under consultation will go ahead as planned (such as the restrictions to interest deductions and carried forward tax losses) and he reiterated the Government's commitment to have one of the lowest CT rates in the G20 (17% to President-elect Trump's 15%).

It will be interesting to see what is proposed as part of the R&D tax credit consultation as well as the proposals to register off-shore structures (and any erosion of client confidentiality/legal privilege) and to apply corporation tax to foreign companies in receipt of UK sourced income (both of which will have greatest impact on the private client and off-shore property investment sectors).

But it is employers who will need to take action now following the changes to salary sacrifice arrangements and commence a review of their benefit packages and the impact of additional tax costs. In addition, the proposed changes to IR35 arrangements and public sector employers (and agencies supplying such bodies) will be enacted in April 2017 and although these changes will not apply to the wider private sector, the contracting world will no doubt monitor the impact of the new rules with interest.

Truth be told, there is scant new content for this souvenir special commentary on the very last Autumn Statement. In a year of upheavals, and with the hybrid and interest deductibility rules yet to bite, we should probably be grateful.

A couple of insurance-related developments are worth noting. With W&I insurance increasingly used on large M&A transactions, the UK's rate of IPT (which is on the rise again, from 10% to 12% in June 2017) is becoming a factor to bear in mind when determining the location of an acquisition vehicle. Better news for insurers is the introduction of special corporation and withholding tax exemptions in connection with Insurance Linked Securities.

The OTS has been asked to look at the collection of stamp duty on share transactions. It is difficult to predict how wide-ranging this review will be – whether it might, perhaps, lead to a merging of stamp duty and SDRT, or a filling of the hole still left in the depositary receipts and clearance system regimes by the HSBC decisions. If the review ends up less ambitious, I have a modest request: with funding being pumped into the Northern Powerhouse and the Midlands Engine, could the Government, in return, invest in a stamp machine for London?

It is disappointing that the Chancellor did not respond to pressure from the housing community to remove the 3% SDLT surcharge which applies to the acquisition of build to rent residential blocks. Hopes now rest that this will be addressed in the Housing White Paper also announced today.

The Government has also not responded to calls for it to take its time when introducing the new interest deductibility restrictions. Today the Chancellor confirmed that they will be brought in from April 2017. The Government will widen the provisions proposed to protect investment in public benefit infrastructure which is welcome but only a small glimmer of positivity amongst the gloom. The devil will be in the detail when published in December.

Those of us who had hoped for a change to the wretched contempt for due process shown by the previous iterations of this government were perhaps predictably disappointed by the confirmation that the BEPS based interest restriction legislation will be introduced with effect from April 2017 (several months before is it even enacted). Unfortunately all precedent suggests that there will then need to be a fair few Finance Acts' worth of "minor changes to ensure the measures work as intended" of the type quietly promised to the similarly rushed anti-hybrids rules. The government's unseemly haste isn't only undermining the rule of law: it also flatly disregards the OECD's recommendation that countries should allow sufficient time in introducing their interest barriers for businesses to adjust. Not to mention putting the UK at a competitive disadvantage when it can least afford to do so as against those other states (that is, all of them) who are biding their time.

Even worse still, we have a new announcement that the interest barrier will be applied to banks and insurance companies in the same way as other business sectors. Previously it had been taken as a given that they would need their own regime: maybe I should get out more, but I know of nobody who thinks the government's approach is a good idea. The only explanation for it can be that the self-induced time pressure to get the interest barrier introduced has trumped any desire to get the policy right. Whatever, it certainly won't help the already difficult task of persuading these businesses to stay in the UK post-Brexit.

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