"The key point for business must be the overall state of the economy. Looking at the tax changes, the question is whether overall they make the UK a more attractive place to establish a business, particularly for an overseas CEO who has a choice. I think the answer is no - the good things are largely outweighed by the additional complexities and the tax increases that are being introduced. There are, though, some useful minor deregulatory changes."

"Principles-based approach to anti-avoidance is a landmark change.

Amidst the usual plethora of targeted anti-avoidance measures closing down schemes disclosed to HMRC, aka 'patching up the system', this year's Budget sees a landmark change with the deployment of principles based rules as part of the anti-avoidance toolkit. Judges have been critical of the use of highly prescriptive drafting because they cannot discern the purpose of the legislation, with the result that they are driven to reach arbitrary results (see for example the recent decision in DCC Holdings concerning manufactured dividends). After a long consultation, HMRC have adopted the principles-based approach in two areas that have remained resilient to the impact of targeted anti-avoidance: the sale of income streams for non-taxable capital sums, and the creation of structures to create an interest-like return which is tax-free. The two new principles are:

It is hoped, given the work put in to the consultation by HMRC and their counterparts in business and the tax profession, that this will avoid the confusion and complexity of the complex and arcane anti-avoidance provisions used in the past."

"I would say that the highlights from the Budget are as follows:

"Pension contributions by individuals, broadly with incomes of £150,000 or more, will attract basic rate tax relief only, as from April 2011. Anti-forestalling provisions will deny higher rate relief for individuals who increase their regular contributions before then. As currently drafted, existing contributions will only count as regular if they have been made on a quarterly or more frequent basis. On this basis, an individual who has been making regular annual contributions (typically in order to save trustee administration fees charged on more frequent contributions) will have lost the ability to obtain higher rate relief on future contributions as from Budget Day. Representations are being made to HM Revenue & Customs in an attempt to remedy this gross injustice."

"With the UK economy in recession and the next General Election looming, it is perhaps unsurprising that this year's Budget focused on measures that grabbed headlines and less on technical substance. The so-called 'green' tax measures and increases in personal tax rates appear to be drawing the battle line for next year.

Whilst many of the announcements, such as foreign profits, investment funds and financial products, had already been well publicised, it is the interaction between personal tax rates and corporate tax measures which have provoked the most discussion. The Government is clearly trying to maintain the UK's appeal to the financial services sector with targeted corporate tax measures, but with the increase in personal tax rates, the impending tax code of conduct for banks and the spectre of increased regulation, there must be a genuine concern that there will be a large migration of skills and capital offshore, with the inevitable effect on the UK economy."

"In the circumstances this was never going to be a giveaway Budget, so the absence of good news was to be expected. Many commentators in this publication have previously warned of the damage that the UK's tax system is doing to its international competitiveness. The hike in personal tax rates to 50% (63% when national insurance is included), the scrapping of personal allowances for high earners, the curtailing of pension relief, the debt cap rules (even in their improved form) and the continued uncertainty over CFC reform all combine to make the UK an increasingly less attractive place to do business. It remains to be seen whether the additional income generated will compensate for the potential damage inflicted.

A number of technical amendments are to be welcomed, e.g. the extension of relief in respect of foreign dividends. Also, the increase in the rate of capital allowances is helpful for those businesses that remain profitable."

"Allowing REITs to issue convertible preference shares introduces welcome flexibility in capital raising for REITs. But other changes to facilitate stock dividends and to assist REITs in managing cashflow were sadly absent. Also absent were announcements on residential REITs, though these may emerge as part of an anticipated wider initiative on residential funds."

"There are some welcome glitch fixes, and a few technical items intended to help in the downturn, but we are missing much of the real detail. It is fine that commencement of the debt cap rules is deferred to 2010 to allow further work and move away from what would otherwise be blunt retrospectivity; but the logic of the debt cap remains questionable, and as currently contemplated it will still operate capriciously in some important situations. Those who think tax should be based upon the rule of law continue to await the Code of Conduct for banks with scepticism."

"The increase in the top rate of tax is alarming. Players in the financial sector are mobile and this may be the final nail for London as a leading financial centre.

However, HMRC has been listening to business. The deferral of the introduction of the debt cap which will allow time for consultation is helpful. Some other sensible amending legislation to help tax systems operate more effectively have also been introduced. These include provisions extending circumstances in which gains and losses in a group can be offset, bringing us closer to group tax consolidation.

As expected, avoidance is targeted. It will be interesting to see the effect of code of practice on taxation for banks, which it is understood all banks will be expected to sign up to."

"It is intriguing to see the populist rhetoric behind the personal tax increases which have stolen the headlines. The Chancellor admits 'we need to retain our position as a world centre for finance' but also says we must 'harness the strengths of the financial services sector for the benefit of society', as if the sector and the hundreds of thousands of people who work in it are not already a contributing part of that society! I am therefore awaiting with some dread the promised Treasury paper on regulation of corporate governance and remuneration in banks and hedge funds. He has now surprised London with tax rates for high earners which will soon be more than New York, Paris or Frankfurt (let alone Zurich or Dubai). Seemingly the resulting tax increases are pure politics - they will raise little, if any, revenue. I think the Government have got it badly wrong - this aspect of the Budget can't fail to knock the UK's reputation as a place to do business and create wealth. Measures which might raise material tax revenues, while being less internationally damaging - such as a VAT rate increase - will have to come next year, possibly from a new government."

"We welcome the decision to introduce the broad dividend exemption from 1 July 2009, though questions still remain about the treatment of foreign dividends in the hands of smaller portfolio investor companies. Equally, news that the introduction of the worldwide debt cap will be delayed until accounting periods ending on or after 2010 will at least provide a welcome breather to enable multinational groups to come to terms with what will, undoubtedly, be an extremely complex set of tax rules.

The decision to make chief accounting officers personally liable for the tax compliance machinery of large companies smacks of a knee-jerk reaction. Some may feel aggrieved that they are being targeted as a result of the failure of the broader risk based models in the financial sector. As a measure, it certainly does not sit well with recent real gains made in the relationship between HMRC and large businesses."

"The new 50% income tax rate is another step towards closing Britain's doors to internationally mobile entrepreneurs. The new higher rate of tax will discourage internationally mobile entrepreneurs from coming to the UK, and cause many already here to leave, right at the time when Britain needs them most.

Whilst the tweaks to the remittance rules are welcome, this is further demonstration that the rules were not properly thought through before being implemented.

The Government seems to be determined to put the squeeze on the wealth generators, and it seems clear that the Budget proposals will not raise enough cash for the Government's needs. Wealthy clients will be concerned about what further changes will be proposed next year and we may start to see an increasing exodus of wealthy individuals from Britain."

"This is a very disappointing Budget from a property tax perspective. Although the Property Industry and practitioners made a good case for tax reforms, for example, in relation to the REIT regime, empty property rates and SDLT on leases, these have largely been ignored and I hope this is not seen in the future as a lost opportunity."

"This is a tough budget for business. The crack-down on 'unacceptable' tax avoidance shifts up a gear. With the introduction of 'principles-based' legislation to counter avoidance, we are moving further towards having a General Anti-Avoidance Rule based system. We also have the introduction of a 'naming and shaming' policy that aims to stigmatise those companies who act in a manner that HMRC considers is egregious. The long-term cost of this policy will be the shattering of the bulwark of taxpayer confidentiality."

"The newspaper headlines have been grabbed by the attack on high-earners.

The 50% tax rate, restriction on relief for pension contributions, the withdrawal of personal allowances and the rise in National Insurance contributions, will all make the UK a less attractive place to be. It may even encourage some executives at companies which have engaged in emigration schemes to add some substance to their new corporate headquarters by taking up residence there. We will have to see whether it actually results in many other businesses, particularly in the asset management and hedge funding industry, relocating abroad.

The Budget included a welcome announcement that the proposed exemption from tax on foreign dividends will be implemented and will be extended to small companies. Those who held out a vain hope that the debt cap rules might be dropped were disappointed, but at least the deferral of their introduction until 2010 may allow some time for the proposals to be refined further.

Another theme, yet again, was the continued assault on tax avoidance. There is the usual raft of anti-avoidance provisions, many pre-announced, which will add more complexity to the system and a promise to review (i.e. extend) the tax avoidance scheme disclosure rules. Perhaps the most eye-catching was the new obligation on senior accounting officers to certify that internal accounting systems are adequate for tax reporting purposes or face personal liability. I can't imagine many willing volunteers in UK boardrooms for the role of 'senior accounting officer'."

"From the perspective of business, the introduction of the long-awaited package on the taxation of foreign profits, in particular the tax exemption for foreign dividends, is welcome and likely to be of most interest. Whether it is effective in attracting business to the UK, or indeed keeping existing businesses in the UK, remains to be seen. Finalising the worldwide debt cap arrangements and any subsequent overhaul of the CFC regime will be important components. The replacement of the Treasury consent provisions and lack of extension to the unallowable purpose rule both represent steps in the right direction. But there must remain a risk that the final outcome of the worldwide debt cap provisions, both in terms of the economic effects and the administrative burden of them could outweigh, or at least diminish, the benefit. It will also be interesting to see if the tax hike for high earners, both in terms of increased income tax rates and decreased pension contribution deductions, will counteract the positive effect of this package."

"The various provisions relating to UK and offshore funds are welcome, and build on the asset management industry's responses to HMRC consultations and other discussions. There are still uncertainties on the scope of some of the measures. It is disappointing that the SDRT charge on authorised investment fund redemptions has not been reformed."

"The corporate tax aspects of the Budget are made relatively less exciting by the political background and state of the national finances, as well as by the extent of prior announcements. For the bits which are interesting, in many cases the detail will only be available once we have the Finance Bill. That said:

"The staggered introduction of the Foreign Profits package is welcome. However, although some of the problems with the original draft Debt Cap rules are to be patched up, the rules remain unduly complex and anomalous. It is disappointing that the Government did not listen to the fundamental policy objections to the Debt Cap regime. It will be interesting to see now what the Government do with the CFC code.

It is not surprising in the current economic climate that the Budget was heavy on anti-avoidance measures, a theme which will no doubt continue in the coming years."

"The new approach to encouraging tax compliance by imposing individual liabilities on senior accounting officers to certify the adequacies of their group's tax accounting system and the ability to 'name and shame' deliberate tax defaulters will raise some interesting issues; the former because of the complexity of most group's international tax (and accounting) affairs, and the latter because the meaning of 'deliberate' is as yet untested. Companies' accounting systems are designed to comply with accounting requirements, not tax, and tax requirements not uncommonly override accounting treatment. The amounts HM Treasury estimate they will gain from these provisions is in the tens of millions, but it is not clear whether this is from penalties for non-compliance, or from tax which would not otherwise have been paid.

In addition, a further round of section 20 notices to banks in a bid to uncover more of their customers' undeclared bank accounts would seem to be imminent.

The introduction of a code of practice for banks will also raise some interesting issues.

The heads of tax in banks and other financial institutions will have to give serious consideration to how they will comply with these new requirements, whilst also taking into account their duties to their shareholders and customers."

"Whilst the initial reaction to the Budget will focus on the headline tax rate rises, when the dust settles it will be noticed that there are genuinely attractive incentives for business to invest in infrastructure and assets over the next 12 months or so. In particular, the first-year capital allowance for plant and machinery expenditure will benefit those in the transport sector as well as other industries and the increase in ROCs for offshore wind farms reaching financial close before 2011 will provide real financial incentives for the renewable energy sector."

"For business, much of the Budget was heralded in earlier announcements and consultations. However, there were a few surprises, pleasant and unpleasant! For example, the dropping of the loan relationships para 13 extension is welcome, though the personal accountability of senior accounting officers is no doubt giving executives some pause for thought. It also remains to be seen whether the 50% tax rate for high-earning individuals will adversely impact UK business; in a world where many businesses are geographically mobile, will it deter businesses coming (or indeed remaining) in the UK?"

"Disappointingly, the Chancellor has given little incentive by way of Stamp Duty cuts to kick-start the property market. The only headline change is the extension of the Stamp Duty 'holiday' for residential properties of up to £175,000 so that this will run to 31 December 2009 instead of 2 September 2009, as originally planned. Other helpful changes at the margins are relaxations of the rules providing for favourable Stamp Duty treatment of shared ownership structures and for relief for leaseholders of flats wishing to acquire the freehold of their block. On the other hand, the Chancellor is showing a determination to crack down on use of Stamp Duty avoidance structures by extending the disclosure rules to cover residential properties worth £1 million or more and by requiring taxpayers to notify HM Revenue & Customs whenever they have used a scheme."

"As has been identified, this is a good Budget for Switzerland, Luxembourg, the Channel Islands and other low tax jurisdictions. The emphasis on anti-avoidance and tax compliance, (including the corporate sphere with the introduction of personal liability for the accuracy of accounting systems for senior accounting officers of large companies), together with the accelerated introduction and further increase in rates of personal income tax, establishes the thrust of the Budget as primarily focused on raising additional revenue rather than the introduction of further tax reliefs and incentives designed to stimulate the economy.

Following the proposals announced in the 2008 Pre-Budget Report, there was little that was new in the Budget for businesses (excepting the introduction, on a temporary basis, of a 40% first year capital allowance for specified plant and machinery), although the confirmation that the new regime for distributed foreign profits (commencing 1 July 2009) will now extend to smaller companies will be welcome, as will the deferral until 1 January 2010 of provisions restricting interest deductions by reference to a worldwide debt cap. Given the further changes and anti-avoidance measures announced in the Budget in relation to individual taxation, businesses will, no doubt, be grateful that, at least for the present, the corporate taxation regime in which they operate remains comparatively stable. The disparity between corporate and individual rates of taxation (and, within the latter, the disparity between rates of capital gains tax and income tax) can only serve, however, to encourage renewed interest by individuals in tax mitigation structures which will now need to be more sophisticated than simple reliance on increased pension provision."

"Amid all the gloom, there was the welcome announcement of the decision to proceed with the exemption for foreign dividends without further delay, and notwithstanding that the other main piece of the foreign profits package, the worldwide debt cap, has been lagging behind in terms of its design.

The increasing gap between the income tax rate and the corporation tax rate on the one hand, and between the income tax rate and the capital gains tax rate on the other, is likely to increase the focus on income tax mitigation. This will include the partial or total incorporation of partnership businesses and other unincorporated businesses, the design of more tax efficient share incentive arrangements, and remuneration planning generally.

For the asset management industry it was a 'Budget of two halves' with several positive measures offset by the restriction in tax relief for pension scheme contributions."

"The proposed increases on income tax and NIC from 5 April 2010 will make it more important than ever for companies to structure share-based employee incentives so they are taxed as capital. We expect to see much more interest by listed companies in restructuring unapproved share option plans as co-ownership plans as the sharper differential between income and capital for higher-rate taxpayers outweighs the loss of corporation tax relief."

"High earners will be hardest hit by this year's budget. It remains to be seen whether such progressive rates of tax result in the UK becoming a less attractive jurisdiction for internationally mobile employees, with the UK now having some of the highest income tax rates in Europe. The increased gulf between income and capital gains tax rates is likely to result in an increased focus on planning designed to achieve a capital return which will be of interest to tax practitioners.

Some measures were introduced to assist companies hit by the economic climate, but do they go far enough? The ability to carry back of loss relief to three years (as opposed to one) has been extended subject to an cap of £50,000 in the additional years. Real estate companies, in particular, may welcome the temporary increase in first year capital allowances on plant and machinery expenditure to 40%, which can be offset against taxable profits at a time where interest relief is typically lower due to falling levels of mezzanine finance.

The long-awaited legislation on taxation of foreign profits will finally exempt (broadly) all UK companies from tax on foreign dividends. Multinational groups will have to balance this benefit against the much criticised worldwide debt cap restrictions (albeit that implementation of the latter has been delayed to provide companies more time to understand the detail)."

"There is a serious disconnect between the many helpful changes to the UK investment funds tax regime announced in the Budget, following a long and constructive period of consultation between HMRC and the industry, and the potentially hugely harmful effect of the increase in the top income tax rate to 50% announced by the Government, one of the highest among industrial countries. The non-dom changes led many non-domiciled UK taxpayers in the hedge fund sector to reconsider whether they should stay in Britain, although very few actually left. The 50% income tax rate is likely to be the straw that breaks the camel's back, particularly as many managers are currently struggling or reviewing their operations. I believe that the next 18 months will - unfortunately - see a significant exodus of talent which could severely impact the recovery of the UK services industry on which the economy is so reliant, beyond the short term."

"Banks will be concerned about the announcement of a draft Code of Conduct for the Banking Sector, which will presumably seek to require banks (including UK branches of foreign banks) to comply with the spirit, as well as the letter, of the tax code. That, coupled with personal liability for the adequacy of the large companies' internal accounting systems, the naming and shaming of deliberate tax defaulters, the proposed (and seemingly unnecessary) extension to the disclosure rules, and the mechanism whereby HMRC will actively 'discourage' potential users of tax schemes is likely to represent a significant change to the climate for tax planning."

"Newspaper headlines will no doubt be dominated by the increase in the top rate of income tax from 40% to 50%.

Tax advisers will at the end of the month be faced with yet another fat Finance Bill.

For business, now having a start date for dividend exemption is welcome news. A deferred date for introduction of the debt cap is also welcome and should give enough time for groups to analyse their tax position and, if necessary, take remedial action before the legislation becomes 'live'. The challenge will be to finalise appropriate, comprehensive and comprehensible legislation based on HMRC's update note of 7 April prior to enactment of the Finance Act.

In what was more of a political than a technical Budget, anti-avoidance was given its own Treasury press notice ('Protecting tax revenues') and was also mentioned in the Chancellor's speech. Some assistance is given to tax directors in these tight cost-control times – finance directors may now be more willing to authorise additional expenditure on internal systems to cope with the significant compliance obligations inherent in the UK's complex tax system. But this may be of limited comfort given the new statutory obligation imposed on the senior accounting officer.

Finally, business should be cheered by the fact that we will shortly have an HMRC 'spotlight' to go with the anti-avoidance group 'signposts', so presumably no-one will be in the dark about when planning is anti-avoidance!"

"The somewhat predictable theme for the City from the Budget is the continued clampdown on tax avoidance with further 'schemes' being plugged under the disclosure rules, a new FOREX TAAR, and the proposals to tighten the disclosure rules by extending the hallmark indicators of tax avoidance and to bring in tougher penalties for non-compliance. For higher-earning individuals, there is the double whammy of restrictions on relief for pension contributions plus the 50% tax rate from next year (with restrictions on personal allowances). Any non-dom who chose to go on the arising basis this year would be well-advised to think again for next year and after."

"One of the main changes in the Budget, which hadn't been the subject of extensive previous consultation, was a series of new measures to ensure compliance by businesses and to discourage the use of avoidance schemes. These include the personal penalties for senior accounting officers, the naming and shaming, and the list of avoidance schemes. Clearly HMRC are determined to continue the focus on ensuring they get the tax they think is due. It will be interesting to see how they work in practice. You wonder whether the list of avoidance schemes is going to put sufficient taxpayers off or whether it will help to provide publicity for schemes taxpayers might not otherwise be aware of."

"The significant difference in the tax treatment of income and capital gains will encourage fuller use of HM Revenue & Customs tax advantaged share plans, and prompt employers to use more complex employee share plans to deliver rewards that are taxed at no more than 18%, rather than the proposed 58.1% on the exercise of unapproved share options from 6 April 2011."

"Clearly the 50% tax rate is controversial. Additionally, however, such a large difference between the rates of tax on income and capital is a recipe for tax avoidance, particularly for owner-managed businesses. Given current attitudes at HMRC and the Treasury, this will inevitably lead to more anti-avoidance rules, renewed enforcement of existing rules, and additional complexity and uncertainty in the tax system. The best way to stamp out tax avoidance is not through increasingly complicated anti-avoidance rules - such as those on selling income streams and disguised interest - but to have a system that does not incentivise people to receive profits in one form rather than another.

Otherwise, the previously announced move to an exemption system for foreign dividends is welcome, but not necessarily at the expense of the worldwide debt cap which, despite the proposed changes, is still likely to be unattractive for many groups and administratively cumbersome. Additionally, the proposal to make senior accounting officers personally liable for adequacy of internal tax reporting systems seems excessive, given existing legislative requirements."

"Multinational groups will be pleased that the Treasury has moved to correct some of the deficiencies of the previous 'debt cap' proposals. However, it is important that the proposed debt cap targeted anti-avoidance rule to be set out in the Finance Bill truly is appropriately 'targeted'. Overseas investors probably expect to have to ensure that any debt finance of UK subsidiaries is on arm's length terms. However, if they find that the ability for a UK subsidiary to obtain a tax deduction for even arm's length intra group interest depends on ill-defined subjective concepts, the lack of certainty could act as a significant deterrent to inbound investment. That could be just as damaging for the UK economy as the measures which have caused UK headed groups to 'relocate' overseas."

"Of the substantive reforms, the most welcome is the confirmation that the foreign profits reforms will come into force on 1 July. The final package is a great improvement on the original proposals and shows the value of a proper and genuine consultation.

In relation to compliance, the Government appears to have been emboldened (with somewhat worrying results) to take a more aggressive approach following recent press and political focus on tax avoidance. Finance and tax directors will doubtless have particular concerns about the requirement upon senior accounting officers of large companies to certify that they have adequate accounting procedures in place, on pain of a £5,000 penalty levied on them personally. This may be particularly difficult to apply fairly to inward investors, as the only individuals with the knowledge to sign off on such an assurance may well be based outside the UK.

The consultation on the role of agents is also ominous, implying as it does that HMRC will assume some sort of regulatory function over tax practitioners. Whilst HMRC will doubtless argue that the compliant agent has nothing to fear, it is not hard to imagine HMRC threatening the use of such powers to put pressure on agents who are legitimately defending their clients' interests. Strong safeguards will be needed to ensure that HMRC can only use these powers where it has well-founded concerns about the agent's integrity or competence, and not merely because it finds the agent's approach uncongenial."

"It is good, finally, to have a timetable for the implementation of the exemption for foreign dividends and related changes. The extension of the exemption to all companies is likely to be welcomed, as is the postponement with further review of the proposed loan relationship and derivatives anti-avoidance legislation. Rather concerning is the 'naming and shaming' of taxpayers who 'deliberately' understate tax due or overstate claims or losses to the tune of tax of £25,000 or more. It is to be hoped that taxpayers who make genuine mistakes won't be caught in a 'deliberate' net."

"Tax advisers had better reinforce their desks to withstand the weight of the Finance Act 2009 given that the Press Releases that sketch out the proposed legislation are 222 pages long. There are some welcome reliefs for businesses struggling in the credit crunch, notably the extension of the ability to carry back losses from one year to three years, where such losses were made in the current market (losses made between 24 November 2008 and 23 November 2010) and the temporary availability of 100% first year allowances. However, someone has to pay for such largesse and for the government bail-outs and individual high earners (those earning more than £150,000) may be forgiven for thinking that they are being singled out as from the next tax year they will pay income tax at 50%, will lose their personal allowance and the ability to claim higher rate tax relief on contributions into their pensions, and will pay tax at 42.5% on their investment dividends."

"The Chancellor in his speech mentioned 'tax avoidance' and 'tax evasion' as two separate concepts, but very much in the same breath and apparently now viewed in much the same way. As long as we have more and more complex legislation, people will always want to look at the detailed working of the rules and see if they can put themselves on the right side of the line in order to achieve a saving, under the laws currently in force. A further increase in the differential between the 18% CGT rate and a new 50% income tax rate for 2010-11 (and lengthy advance warning of that 10% income tax increase) is only going to add fuel to the fire. Better to have simpler legislation and flat rates across the board (as Nigel Lawson introduced in 1988). But with 93 Budget Report Notes and a host of other material, there's no sign of that penny dropping.

The dogs that didn't bark in the night are sometimes as interesting as those that did. Nothing much about relieving the current National Insurance contributions burden for employers and employees nor changes to the major differential in rates between employed and self employed persons. That leaves LLPs still looking of interest as a vehicle for businesses employing numbers of high earning individuals. The increased 50% top rate of income tax will add further to the tax costs (as compared to the position of a limited company) where profits of an LLP need to be reinvested in the business, but may equally be an added incentive to look at the overall tax efficiency of the current business vehicle."

"For business, there were two principal messages from the Budget: 'steady as she goes' and 'we're keeping an eye on you...'. Most Budget announcements by HMRC related to the advancement of measures that are the subject of existing consultations (and where any controversy has largely been played out already). HMRC have equally made it clear that compliance and non-compliance are firmly on their agenda (which comes as no surprise given the need to raise and collect tax cash); what is a little surprising is the tone of some of the thinly veiled threats on stamping out potential avoidance. HMRC are going to take a tough and firm line with taxpayers for the foreseeable future."

"For multinational groups the main news relates to the foreign profits package -- where the postponement of the debt cap and the shelving of the extension to the 'unallowable purpose' rule for interest relief are both positive. The wild card is the introduction of a SOX-type rule for large groups which obliges their 'senior accounting officers' (e.g. the CFO) to certify annually that the company's accounting systems are adequate for the purposes of accurate tax reporting, with any inadequacies notified to the auditors. For many groups this could be an extra burden at a time when costs and resources are already under strain."

"The Budget contained a number of welcome announcements on the finance side. The previously proposed extension of the loan relationship and derivative contract unallowable purpose rules, forming part of the foreign profits package but which would have applied generally to all UK corporates, has been delayed, at least for now. In addition, the introduction of a set of reliefs to facilitate the raising of Islamic finance bonds backed by UK real estate represents a significant step forward in establishing a level playing field between conventional and alternative finance instruments.

On real estate investment trusts, there has been minor tinkering with the existing rules, coupled with the confirmed introduction of an anti-avoidance rule to prevent REIT status being obtained by companies for whom it had not been intended, but progress remains to be made on other areas, such as ironing out difficulties under the joint venture rules. In addition, taxpayers' proposals that the 90% property income distribution requirement should be deferred or waived given the current financial climate, or to allow the PID to be paid in scrip rather than cash, have not been adopted, which will be a disappointment for some."

"In relation to VAT, there is very little that is new or unexpected in the Budget.

The thresholds for registration and de-registration have increased slightly to £68,.000 and £66,000 respectively. In like vein, there was an increase in the threshold at which retailers must use bespoke VAT retail schemes to £130 million.

More significantly, a new simpler procedure for opting to tax property will be introduced. This change should allow land owners who have made exempt supplies to opt to tax future supplies of land or buildings more easily from 1 May 2009. Also in the area of property, a specific provision will be introduced to overcome the problem in relation to VAT and the rent review provisions in the Agricultural Holdings Act 1986 identified in Mason v Boscawen.

There will be further legislation in relation to the change in rate from 15% to 17.5% at the end of this year. In particular, anti-forestalling legislation already released in draft will be in the Finance Bill. The legislation is aimed at businesses which cannot fully recover VAT and will prevent them manipulating the time of supply rules to pay VAT at 15% on supplies which should properly be regarded as liable to VAT at 17.5% because they occur on or after 1 January 2010.

The biggest change of all (and also the one that was most predictable) is the introduction of legislation to implement the VAT Package. This changes the rules on the place of supply of services supplied between businesses in different countries. There will also be related changes to the time of supply rules, obligations to submit European Sales Lists (which affect services for the first time) and a new refund procedure for Eighth Directive refund claims."

"Aside from the headline changes in income tax rates, we have the not-unexpected limitation on relief for pension contributions for high earners. The measure is expected to raise just over £3 billion a year from 2012-13 onwards. As with the revenue from the income tax increases, this is a drop in the ocean of the overall deficit; the pretence that the gap can be filled without broad based tax increases is not sustainable. Apart from the individuals themselves, this will deal a significant blow to the pensions industry, which given recent fund performance is already finding it difficult to attract savings. The statistics produced by the Chancellor to show how much of the total value of the relief is currently given to the highest earners also demonstrate how much of the total amount paid into pension funds comes from those high earners. This measure may lead to at least some of this substantial amount of capital being redeployed in unpredictable ways, to the detriment of companies trying to raise funds. It may also contribute to the growth of less regulated parts of the financial sector, putting further stress on the increased regulatory measures which are also to be expected.

As expected, measures have been introduced to limit the scope of the anti-avoidance rules causing UK companies to obtain interest relief on a paid basis rather than the normal accruals basis. Whilst the Government sees this as a helpful change – and for many companies it is – the private equity industry will continue to be concerned about a real lack of clarity as to how the legislation will apply where interest is paid to partnerships. If there were to be an unhelpful interpretation, the change could lead to substantial amounts of trapped losses within typical private equity funding structures as well as significant administrative burdens. There is better news in the context of interest deductibility elsewhere: the extension of the purpose-based anti-avoidance provision formerly contained within paragraph 13, schedule 9, Finance Act 1996 mooted as part of the foreign profits package has been parked for now."

"This seems to be a highly political Budget that may well reduce the attraction of the UK to highly skilled senior executives/entrepreneurs. These changes come at the very time when other onshore jurisdictions, such as Switzerland, Spain, France and Australia are seeking to attract just such able migrants. Quite how these threatened tax changes may help our benighted economy remains to be seen."

"A mixed reaction from to me to the foreign profits proposals. Delighted that the Government has postponed the debt cap proposals until next year; this will hopefully give them time to sort it out so that they are workable. Less pleased that while we are to have a dividend exemption, they have not listened to the representations asking for the starting point to be that dividends will be exempt rather than taxable unless they fall into one of the specified exempt classes."

"As ever, this year's Budget is a mixture of the previewed, the predictable and the unexpected.

A large amount of the measures in the Budget have already been announced and, in some cases, subject to detailed and ongoing consultation. These cover areas such as foreign profits, transfers of income streams and disguised interest. One pre-announced provision which will not now form part of the Finance Bill is the proposed widened anti-avoidance rule for loan relationships and derivative contracts. The proposed provision was broad and uncertain in its scope, and so its omission from the Finance Bill is to be welcomed.

The increased rate of income tax and restrictions on pension relief for higher earners sounds like something from Robin Hood. The risk for Robin is that in the next chapter the Sheriff of Nottingham might decide that he would rather carry on his highly mobile financial services business elsewhere, depriving Robin of a major source of income.

One significant new measure is the introduction of 'personal tax accountability' for senior accounting officers of large groups of companies. These individuals will be required to establish and monitor accounting systems which are adequate for the purposes of accurate tax reporting, and to certify annually that the accounting systems are so adequate, or alternatively to specify any inadequacies which must be notified to the group's auditors. The Government's view is that because adequate accounting systems should already be in place this should not impose a significant burden. What will really focus the minds of senior accounting officers is the fact that they (as well as the company) could be personally liable to penalties for any careless or deliberate failure to comply properly with their obligations.

A useful technical change is to be made to Section 171A of the Taxation of Chargeable Gains Act 1992. As it is currently drafted, this section allows a company selling a chargeable asset to company outside its group to elect that the asset is deemed to have been transferred to another group member before its disposal, enabling it to make use of eligible losses in that other group member. The requirement that the asset is sold to a company outside the group means that this provision cannot be used for some losses or gains, such as losses arising from a negligible value claim or where an asset is transferred to another group company which is not within the charge to UK tax. Section 171A is to be amended so that rather than deeming the asset to have been transferred, the actual loss or gain will be transferred to another specified company within the group, and the former restrictions on the type of asset and the circumstances under which the gain or loss arises will no longer apply."

"Leasing: Usually the Budget is a harbinger of doom and gloom for leasing companies, and we all look to see which avoidance schemes have been disclosed, what have HMRC decided to hammer this year. Probably it's the credit crunch suppressing everyone's appetite for deals, but still it's quite nice to see only the one press release on leasing anti-avoidance, and another (gasp!) where HMRC are actually trying to be helpful. The devil will be in the detail, but with BN12 it looks like HMRC have finally taken on board the fact that the sale of lessors provisions just don't work properly.

Funds: It's always fun on Budget Day when, tucked amidst all the stuff we were expecting (new definition of offshore fund, new tax elected funds regime, new white list for trading activities, new rules for investment trusts) we find a press release saying, 'oh by the way, transparent offshore funds won't actually be transparent for CGT purposes anymore (unless they're partnerships)'. Did we all blink and miss HMRC's detailed consultation on this? It's a bit of a leap from their throw-away comment last December to this.

Foreign profits: Well, the goods news is we don't have to worry about 'super para 13' any more, and at least we'll get the dividend exemption before we have to apply the debt cap. The bad news is...well, everything else, really. HMRC have taken on board some of the concerns of business, but not nearly enough - we'll have to wait and see if the detailed drafting of the Finance Bill proves up to the job of making the debt cap a workable measure in practice, but it may be forlorn to hope that tax managers won't have an additional hefty compliance burden from next year."

"At this time of deep recession, one would have thought that every measure would have been directed at enabling UK businesses to get back on their feet. The dividend exemption, loss carry back and changes to the ring fence regime are some of the well-directed introductions, though time will tell if this is enough to encourage those who might redomicile to reconsider.

But this Government is totally obsessed with anti-avoidance and restrictions. Is this really the time to distract business with further complex rules? Could not all of these measures (including the cap) have been put off for a couple of years until business is making enough profits to start paying tax again? And a further worry is that the time for scrutiny of complex rules has now been crammed in between the very late Budget Day and the insensitively early departure of our lawmakers to their holiday homes.

I'm also sceptical about the impact of doubling the main rate of capital allowances. It's only useful if you can borrow and are paying tax at the right time and few are in this position at the moment. The traditional alternative is for a lessor to use the allowance and lease to the user - but the banks can't really do that at the moment. What's needed is a brand new easy-to-use system which would allow those with money and tax capacity to invest in the assets business needs and lease them on."

"My own take on the Budget is that it is largely unsurprising and that, whilst it contains some helpful measures, overall it is unlikely to lead to any material changes in business behaviour.

I note that many economists rather doubt the Chancellor's optimism as to the timing and speed of any recovery and, from a tax perspective, I cannot imagine that the revenue raising measures (such as increasing the proposed new top rate of income tax to 50% and accelerating its introduction by a year to 2010) will make much of an impact on the budget deficit.

Some specific tax measures that will be of interest to businesses generally include the enhanced 40% first year capital allowances, the maintaining of the VAT rate at 17.5% when the lower 15% rate expires at the end of this year, and the proposals that appear now to have been almost finalised in relation to foreign dividends and the worldwide debt cap."

"The spirit behind the Budget is neatly illustrated by the proposal that those who are penalised for deliberately failing to notify tax of £25,000 or more should have their names published. Deliberately concealing tax liabilities is a serious offence of dishonesty and those whose names are published will be castigated as criminals. Fine if they did it of course, but the 'well probably' test for civil penalties cannot be right in this context. No doubt the Revenue would find this sanction 'useful' in negotiation but penalties of this severity should only be imposed on the basis of proof beyond reasonable doubt. There is nothing about that in the Budget notice. In any case, the fact that the rules would only apply where the tax lost is more than £25,000 raises the spectre of the threat of publication being understood as an acceptable negotiating ploy."

"In general, this Budget is hardly a recipe for motivating increasingly mobile taxpayers and individuals to greater economic endeavour and reducing the rush of UK companies migrating.

On specifics, among other measures, we have reservations about the proposals to make senior accounting officers personally accountable to HMRC for their companies' tax reporting systems; we have real concerns it could, however unintentionally, create a back-door Sarbanes-Oxley act for business. We hope that HMRC will take seriously representations from business in consultation on this measure.

The new foreign dividend rules are the bare minimum the government can do to comply with EU law. We remain concerned about aspects of the worldwide debt cap rules, which will require careful planning to avoid traps and minimise anomalies.

Careful planning will be needed by businesses making cross-border supplies to reflect the changes in their VAT treatment, some of which will come in as soon as January 2010."

"Quantative easing appears not to extend to the 2009 supply of new Budget Notes. The Government's macro-economic strategy for recovery continues to rest on generic optimistic forecasts, rather than particular micro-level fiscal policy; that notwithstanding, by international business professionals, the 1 July timetable for the 'new' taxation of foreign profits regime (but without the attendant loan relationship and derivative anti-avoidance rules) will be welcomed, unwelcomed will be the new revenue protecting proposals to 'name and shame' tax defaulters and personal accountability for senior accounting officers by all but the most committed of enthusiasts of Reality TV and other pop cultural hegemony."

"The income tax increases will make the big headlines – far from recapturing the wealth of those who got rich in the boom as the Chancellor claimed, they will de-motivate those attempting to generate the wealth which can pull the economy out of recession. When the employers' and employees' national insurance increases announced last year feed through as well, the total tax burden on salaries over £150,000 will be 64.8% - this is dangerously uncompetitive if, as the Chancellor states, it is an objective to maintain the UK's leading place in the worldwide financial securities industry. When the banks come to re-hire as the world economy improves, this rate will be a powerful disincentive to grow in the UK. If the aim is to tax riches already made in the boom time, significant inheritance tax increases – including a reversal of the cuts introduced as a panic measure in 2007 - would appear a far better measure. It is not as if the income tax increase is even particularly lucrative, as it is only slated to raise £2.4 billion per annum by 2012-13. Basic rate income tax and/or VAT will have to go up, probably significantly, after the general election.

Of the greatest significance for international businesses is the inclusion of the changes to the taxation of the foreign profits of UK companies. The Government is scrambling to get these ready in time: whilst the new dividend exemption proposals are in good shape, attempts to address the issues associated with the world wide debt cap (WWDC) remain troublesome and still open for consultation in some respects even at this very late stage. The Government is unwilling to accept that the policy underlying the WWDC is fundamentally flawed, and attempting to fine tune the measure puts one in mind of silk purses and sow's ears. There is doubtless an awareness in the Treasury that failure to include the measure in this year's Finance Bill may mean it is lost, as due to the electoral timetable nothing contentious is likely to be able to be included in Finance Bill 2010. Introducing the dividend exemption is imperative, as the UK's existing code for the taxation of foreign dividends has been held to contravene the EC Treaty; the WWDC would seem to follow as the Government continues to insist that the exemption must be seen as part of a package with the WWDC despite the absence of any obvious conceptual connection between the two."