Fairness was the cornerstone of the Chancellor's pre-Budget statement on November 3.

The three main components of this 'fairness' system are pursuing tax evasion, artificial avoidance and simplifying the existing tax law.

It was no surprise that the General Anti-Avoidance Rule did not go unmentioned.

The Government's idea of fairness seems to be to introduce measures which may sound appealing but which will further burden the taxpayer.

Corporate Tax Self-Assess-ment and the abolition of ACT were introduced at around the same time. The abolition of ACT was to benefit companies as they would not need to make interim payments.

However, CTSA means companies will now need to make quarterly payments placing a larger burden on their cashflow.

Smaller companies will benefit from the plans of this Government who wish to encourage inward investment from larger businesses who will, in turn, be entitled to tax relief. This will not only help the smaller companies but also the Government in the form of reduced grants and subsistence payments.

We have yet to hear how the Government will simplify and modernise the tax system but if CTSA has the same impact as personal tax self-assessment, then it is unlikely finance directors will be able to understand the tax implications facing their companies in the near future.

Jonathan Oxley is a partner with Lee & Priestley solicitors.

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