We asked leading tax practitioners for their views on the March 2015 Budget. An overview of their comments is set out below; click on a name to read the comment in full.

For all Practical Law's March 2015 Budget coverage, see: Practical Law 2015 Budget coverage.

We all waited with baited breath for the rabbit out of the hat. The killer blow that would get the Conservatives re-elected. Thrown into the pot for our contemplation were many measures announced in the 2014 Autumn Statement or provided for in the draft clauses published for inclusion in the Finance Bill 2015. There was a sprinkling of reliefs for the oil and gas industry (much needed) and savers (politically savvy). A pinch of action against tax avoidance and evasion was thrown in for good measure. Inevitably, there were the jokes at Ed Miliband's expense, which received looks of contempt from Ed Balls (but, hey, at least he didn't essentially call him Gromit again)!

But was it enough? Perhaps. According to Simon Skinner, Travers Smith LLP it was "[a] politically astute General Election year budget by a Chancellor who has grown more confident in his delivery year on year" and "[w]hile unsurprisingly thin on major announcements, there are enough targeted measures to catch the attention of the press."

Frankly though, there was little magic. It was arguably, as Charles Goddard, Rosetta Tax LLP said, not "so much a Budget, more advance publication of the Conservative Party's election manifesto" with "[a]nything of significance (and there was little for business) [being] left till after the election."

Many seemed pleased that the government appeared to have listened to issues raised during consultation on the draft Finance Bill 2015 clauses. However, concern was expressed at the speed with which the Finance Bill will be enacted. It will be introduced to Parliament on Tuesday 24 March, debated on 25 March and enacted on 26 March. This prompted Susan Ball, Clyde & Co LLP to comment: "one wonders why we cling to the fiction of Parliamentary scrutiny of tax legislation."

Osborne's unexpected (or at least not previously announced or leaked) package of measures relating to entrepreneurs' relief received a mixed response. Arguably, there was somewhat of a fine balancing act: taking with one hand, while giving with the other?

The measure that attracted the most attention was the restriction on the "Manco" structure. As explained by Barbara Allen, Stephenson Harwood LLP "[t]his mechanism has been widely used for managers in private equity portfolio companies." It enabled individual directors, each owning at least 5% of shares in a management company with no trade of its own that owned as little as 10% in a trading company, to qualify for the relief. Following the change, only those with a 5% direct shareholding in a genuine trading company will qualify. Caspar Fox, Reed Smith LLP agreed with HMRC stating that "this is an example of where the legislation was being used in a way which was inconsistent with the underlying principles of the relief." James Hill, Mayer Brown International LLP concurred, commenting that the announcement "is unsurprising", but he did find it surprising that "the Manco route has been closed down with immediate effect." However, perhaps, as pointed out by Jonathan Cooklin, Davis Polk & Wardwell LLP, it is "a little surprising the planning targeted has lasted this long." Conversely, Colin Kendon, Bird & Bird LLP considered that the structure "was designed to circumvent a basic unfairness in the entrepreneurs' relief rules" and hopes that the government's next step will be to "abolish the 5% personal holding company test altogether."

While many focussed on the Manco structure, Jeremy Webster, Pinsent Masons LLP commented that "the measure to prevent entrepreneurs' relief on the sale of goodwill to a related company, coupled with the restriction on relief for internally-generated goodwill transfers between related parties, will make incorporating a business far less attractive to many entrepreneurs and is likely to have a greater impact in the long term." Nonetheless, John Christian, Pinsent Masons LLP considers that the changes "do not affect the fundamentals of entrepreneurs' relief which remains a generous relief and reflects the [g]overnment's view of its powerful incentive effect for business owners."

Erika Jupe, Osborne Clarke welcomed the extension of entrepreneurs' relief to academics disposing of shares in university spin out companies that exploit intellectual property stating that it "will cover a gap which was left when [the relief] was extended to EMI option holders." But, as warned by Nicholas Stretch, CMS Cameron McKenna LLP, some of the issues raised at the time of extending to EMI options, such as the trading status of the company, will need to be addressed. Previously, these ended up "in the too difficult pile and so there will need to be some extra impetus this time round for any changes to occur."

Commenting on Osborne's announcement that corporation tax loss refreshing would be closed down with immediate effect, Tony Beare, Slaughter and May stated: "It is perhaps inevitable given the state of the economy over the past [seven] years that the [g]overnment would seek to restrict the utilisation of losses as a means of raising revenue." Nonetheless, Charlotte Sallabank, Jones Day felt the move was "surprising as freeing up trapped losses has not been at the forefront of perceived avoidance" and it adds a further "element of uncertainty" for corporates entering into transactions.

David Wilson, Davis Polk & Wardwell LLP warns that it is a "complicated area with real scope for collateral damage." But, as highlighted by Richard Carson, Taylor Wessing LLP, "it looks as though a certain amount of care has been taken to minimise the risk of commercially motivated arrangements (or conventional group tax planning) being caught". How it goes about this is not so clear and led to Eloise Walker, Pinsent Masons LLP awarding the draft legislation her "personal prize for 'Most-Impenetrable-Draft-Legislation-in-a-Budget'" and "offering a modest box of chocolates to any reader who gives [her] the best explanation of exactly how anyone is supposed to apply the hypothetical 'it will be reasonable to assume' test of the economic benefit versus the tax value." Ashley Greenbank, Macfarlanes LLP agrees that "the application of [the motive] test is likely to present the most difficulties in practice."

It is not all bad news though, at least possibly not for tax advisers. If Adam Blakemore's, Cadwalader Wickersham & Taft LLP predictions are correct "[l]egal documentation is unlikely to become any simpler, or shorter, as a result of these new provisions" and "[d]rafting relating to the utilisation, or unavailability, of historic tax losses in M&A tax indemnities is likely to be looked at very closely once these provisions are enacted." All potentially lucrative for the legal and accounting sectors!

To the despair of many, the government confirmed that diverted profits tax (DPT) will come into force on 1 April 2015. Many had hoped in vain that the start date would be pushed back and, as Hartley Foster, Field Fisher Waterhouse LLP pointed out, "[b]ut for the desire to grandstand before the election, the introduction of DPT may have been postponed until after the end of 2015, when the OECD will have released its BEPS report that will address the shifting of profits of multinational groups to low tax jurisdictions." Andrew Loan, Macfarlanes agreed, commenting that "[n]o doubt the haste is driven by political considerations, but it is rarely sensible to make tax law in a hurry."

Simon Yates, Travers Smith LLP summed up the general feeling in his very unique and amusing comment as "a distinct sense of foreboding about the Diverted Profits Tax legislation to be published next week." However, on a more positive note, Richard Sultman, Cleary Gottlieb Stein & Hamilton LLP considered it "(potentially) encouraging to see [the government] have been willing to listen to comments made in the course of consultation". Emily Clarke, Travers Smith LLP, like others, is frustrated that revised clauses will only be seen shortly before the changes take effect and hopes that "HMRC gets it right second time around".

Whether the changes will go far enough to allay concerns as to the scope of DPT and its potentially detrimental effect on undertaking business in the UK due to uncertainty remains to be seen. As Stephen Hoyle, NGM Tax Law LLP stated, "[i]n one sense DPT does no more than extend beyond financing costs the concept underlying the worldwide debt cap" but it will "rely heavily on guidance, assurances to industry groups and advance pricing agreements". This may provide some certainty, albeit not contained in legislation as would ideally be hoped for.

In the lead up to the Budget, the oil and gas industry lobbied for changes to help with falling prices. After suffering the huge rise in supplementary charge implemented following the 2011 Budget, it appeared time to help the struggling industry. The announcement of a 2% reduction in the supplementary charge as part of the 2014 Autumn Statement was helpful, but it arguably did not go far enough. Therefore, the announcement of a reduced supplementary charge of 20%, an investment allowance and a drop in petroleum revenue tax to 35% "will be welcomed by the industry and those whose jobs rely on the North Sea", according to Vimal Tilakapala, Allen & Overy LLP.

Jenny Doak, Vinson & Elkins LLP agreed, but considers that the "industry will continue to press for further initiatives" to assist those "companies not yet taxpaying (such as new entrants in the UK North Sea or early stage companies)."

It seems that no Budget is complete without some measures targeted at the banking sector, especially when it's a pre-election Budget and popular opinion remains steadfastly against bankers. This led David Harkness, Clifford Chance LLP to state: "It remains to be seen if the tipping point has yet been reached at which a major player will leave the UK, but already anecdotal evidence suggests mobile business units are moving abroad and new units are being started outside the UK." Colin Hargreaves, Freshfields Bruckhaus Deringer LLP made a similar point, stating that the measures "can only come with risks both to the levels of lending into the UK economy and to global banks' decisions on where to focus investment."

There was the standard party trick of raising the bank levy (up to 0.21% from 1 April 2015), the already announced restriction on carried forward reliefs and the disallowance of deductions for compensation payments for misselling. But, in addition, there were some more discreet measures that will impact banks.

The changes to the VAT legislation preventing partially exempt businesses from taking into account supplies made by foreign branches when determining recoverable input VAT under the partial exemption rules will be felt particularly by banks (and other financial institutions such as insurance companies). Nick Skerrett, Simmons & Simmons LLP says they "arguably [go] beyond what was envisaged by the [European Court of Justice] in Credit Lyonnais and may be ultra vires EU law." Michael Conlon QC, Hogan Lovells International LLP expects that HMRC will "scrutinise transfer pricing arrangements" as a result, and "[a]ffected businesses should urgently review their partial exemption method and agree any modifications necessary to reflect the changes whilst also ensuring optimum VAT recovery."

Banks will also be hit by the costs associated with the introduction of automatic information sharing (see Tax evasion, avoidance and transparency it's all smoke and mirrors). Andrew Goodman, Osborne Clarke was surprised that HM Treasury estimates that "the administration of the scheme, gathering and distributing information on the residents of all [the] countries, would cost the banking industry only £2-4m per annum. Even allowing for the initial "one-off" costs of £70-209m, this annual estimate must surely be out by a factor of 10."

The banks may find some solace as "the exemption for savings income ... may incidentally save [them] a few bob", according to Richard Croker, CMS Cameron McKenna LLP.

The government had to show that it is cracking down hard on anyone who evades or avoids tax. These measures are of course not only designed to help Osborne reach that much desired surplus, but also to win the votes of the hardworking population. The announcements illustrated what Liesl Fichardt, Clifford Chance LLP termed "a clear shift towards a global (as opposed to mere domestic) approach to the [g]overnment's increased crackdown on tax evasion."

The early closure of the Liechtenstein and Crown Dependencies disclosure facilities was unexpected, but, as Michael Hunter, Addleshaw Goddard LLP pointed out, "[g]iven the recent scandal about HSBC and offshore accounts, it is perhaps not surprising."

As expected, and probably also due to the furore surrounding HSBC's activities, the government announced plans to introduce criminal offences for tax evasion and penalties for professionals who assist. Sanctions for avoidance are also to be beefed-up. Sandy Bhogal, Mayer Brown International LLP commented: "The key point for any such rules will be clarity as to what is acceptable avoidance, at which point tax advisers will know whether they may end up wearing an orange jump suit because they suggested using the quoted Eurobond exemption!!"

Along with others, Martin Shah, Simmons & Simmons LLP welcomes the proposed consolidated regulations dealing with reporting obligations under the EU Revised Directive on Administrative Cooperation, the Competent Authority Agreements with non-EU jurisdictions for the Common Reporting Standard and FATCA as it will "avoid a 'patchwork quilt' of regulations for affected UK financial institutions." He also considers that the removal of holding companies and relevant treasury companies from the definition of reporting financial institutions is "generally positive". Despite this move, Philip Harle, Hogan Lovells International LLP warns that "it is only part of the battle as each jurisdiction imposes its own interpretation of these complex rules."

The introduction of yet another targeted anti-avoidance rule in the form of preventing corporation tax loss refreshing (see Corporate losses: into the vanishing box) led a number of practitioners to comment on the purpose of the GAAR. Nikol Davies, Taylor Wessing LLP summarised it neatly, stating: "What is apparent is that targeted anti-avoidance rules will continue to proliferate despite the GAAR, and that the introduction of tax geared penalties for taxes due to the application of the GAAR will provide a further deterrent to more aggressive forms of tax planning."

The Finance Bill 2015 and legislation to be included in future Finance Bills are hotly anticipated by many. A number of measures concern practitioners since their precise scope and application cannot yet be ascertained. For example, Darren Oswick, Simmons & Simmons LLP stated that the Budget did not address concerns relating to the uncertainty over the disguised investment management fee income rules and "it remains to be seen how far HMRC will have gone in addressing the concerns that were raised." Tracey Wright, Osborne Clarke is keen to see the legislation relating to the restriction of travel and subsistence reliefs for workers engaged through employment intermediaries since "[i]t will be interesting to see how HMRC proposes to draft the rules to capture only employment intermediaries and to ensure that there is no scope of alternative models to evolve." Mark Sheiham, Simmons & Simmons LLP also pointed out that, while concerns were raised over the requirements set out in the technical note for the private placement exemption from UK withholding tax on certain unlisted securities, "HMRC is understood to be listening to such concerns, so it is to be hoped that when the form of the regulations are provided, they may be less onerous than originally feared from the technical note, perhaps sufficiently so that the private placement exemption may be able to serve its intended purpose of supporting the development of a private placement market at least to some extent."

There was a smattering of other measures. Some good, some bad, some perhaps simply aimed at winding up Ed Miliband who will be happy to know that he will soon be able to control both the fridges in his "two kitchens" from one mobile phone.

Naomi Lawton, Memery Crystal LLP commented: "We are assured that coalition government tax policy is not devised solely on the basis that it lends itself to comedy at the expense of the Labour party. However, this was not apparent on Wednesday." The announcement that the government will review the use of deeds of variation for inheritance tax purposes was "seemingly more a side-swipe at the Miliband family than a serious attempt to prevent tax-avoidance", according to John Barnett, Burges Salmon LLP. David Milne QC, Pump Court Tax Chambers certainly hopes that it was simply a joke since "[d]eeds of variation have throughout living memory been an essential family tool, relieving testators of worrying about whether their wills have kept up with latest tax advice".

Ed Denny, Orrick, Herrington & Sutcliffe LLP commented that "changes to the qualifying conditions for EIS/SEIS in the Finance Bill ... look interesting, including the suggestion that split SEIS/EIS financing may no longer be required in light of the announcement that the requirement to spend 70% of SEIS funding before EIS/VCT funding can be raised is to be dropped." Mathew Oliver, Bird & Bird LLP was particularly pleased to see this since it "seemed a pointless measure and unnecessarily distorted behaviour for start ups."

Somewhat taking the wind out of Labour's sails, Osborne announced a cut in the pension lifetime allowance to £1 million, along with the anticipated changes to the annuity rules. Lesley Harrold, Norton Rose Fulbright LLP stated that, no doubt, the annuity trading measures will be "popular with pensioners but there are many practicalities to be addressed before the policy takes effect ... The difficulties will include how the buy-back price of the annuity is calculated, and how the lifespan of the annuity seller is monitored for the purpose of establishing the continued entitlement of the buyer to the annuity income." As Mark Womersley, Osborne Clarke stated: "It's a very bold move, and full of complexities. The Financial Conduct Authority will need plenty of wisdom to ensure that the new market in annuities works fairly and efficiently."

Taxpayers will no doubt be delighted at the scrapping of the annual self-assessment tax return. Although maybe not the 1,773 people who filed theirs on Christmas Day last year. They may now be forced to help with peeling the spuds or, worse, listening to grandparents reminiscing about the "good old days". However, I digress. Paul Concannon, Addleshaw Goddard LLP thinks that "although the prospect of doing away with self-assessment returns is enticing their replacement with a large government IT project is less so." I'm sure that those working hard on the migration of content to gov.uk are likely to agree. They already have a pretty long "to-do" list.

Understandably tremors are still being felt from earlier announcements that were confirmed in the Budget. In particular, Elliot Weston, Wragge Lawrence Graham & Co LLP expressed concern that the capital gains tax charge that will apply to non-residents disposing of UK residential property from 1 April 2015 "opens the possibility that the charge will be extended in the future to include commercial property."

Art lovers' delight at the Court of Appeal's decision in HMRC v The Executors of Lord Howard of Henderskelfe (deceased) [2014] EWCA Civ 278 was unfortunately not to last long with the announcement that the exemption from capital gains tax on wasting assets will be amended. Murray Clayson, Freshfields Bruckhaus Deringer LLP stated: "Now to 'improve the fairness of the tax system' (sigh), section 45 TCGA 1992 will be amended 'to make clear that the wasting asset exemption applies only if the person selling the asset has used it as plant in their own business'. It is to be hoped that the tightening of section 45 will be confined to cases within the subsection (2) exclusion from exemption - where the asset is used in a trade - and will not restrict the exemption more generally [for example,] to the chagrin of fine wine collectors."

It came as no surprise that no major changes to share incentives were announced. As Graeme Nuttall, OBE, Field Fisher Waterhouse LLP pointed out: "Budgets 2012, 2013 and 2014 contained unprecedented support for the employee ownership (EO) business model. After such an amazing era it was expected that the pre-Election Budget 2015 would be silent on EO policy." Yet, there will be "no twiddling of thumbs" according to Judith Greaves, Pinsent Masons LLP because, as Karen Cooper, Osborne Clarke points out "many employers are still grappling with HMRC's new online registration and self-certification procedures!"

There may be have been little new or of substance to ponder on in this Budget. But fear not, we'll all surely be kept busy with the almost inevitable post-election Budget. Of course, not to mention the Finance Bill 2015. In the meantime (all of four days), put your feet up, relax and enjoy that penny off the pint!