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by rossriley 3202 days ago
Well the problem is that you just create a loophole.

You can already avoid paying any corporation tax by taking money out of a company as salary.

In the UK you have dividend tax credit so effectively when you take a dividend you get the tax back that has already been paid (as corporation tax).

So both those reasonable ways of extracting money from a company allow you to not pay any additional tax above what income tax would be.

However if there was no corporation tax then the loophole / incentive would be to move money out of the jurisdiction and extract the dividends in a zero tax country.

This is effectively what the big multinationals do via transfer pricing etc but not having any corporation tax would no doubt make it a lot easier for more companies to do that.

3 comments

This doesn't seem insuperable. The rule could be that any dividend paid to anyone other than a UK taxpayer, or another UK company, is taxed at the top rate of income tax. That would make such a shunt pointless.

You could then extend the existing international double taxation agreements to cover these dividends. So, for example, if a dividend is paid to a Dutch taxpayer, it is not taxed at source, but as income. You might want to retain the current UK arrangement in this situation, though, so as to keep some of that tax revenue in the UK. You wouldn't extend these arrangements to tax havens.

Manoeuvres like the Double Irish or whatever would still get around this, and would still need to be attacked in the way they are (or at least should be) now.

You would need to extend the spirit of this rule to share repurchases, which might be tricky.

> when you take a dividend you get the tax back that has already been paid

Yea, that needs to stop. This idea of being "taxed twice" is ridiculous because companies are not people. If they were then yes they would be taxed twice and it would be "unfair" but then they'd also be taxed at the proper rate.

No, I was explaining that this already happens. Actually at least in the UK the system is just changing over to be more clear so rather than the tax credit you just get a lower rate.

So for instance instead of the 25%ish that you would expect to pay in tax on your income you pay 7.5% on your dividends which is more or less the income tax rate minus the corporation tax already paid.

yeah but your company paid the corp tax, not you. That's isn't fair because your company can offset its losses and individuals cannot. Its not a fair comparison.
>> In the UK you have dividend tax credit

Not any more, that got shelved a few years back AFAICT.

Yes, sorry I did expand in another comment, it's now been replaced with a percentage, but the principle is the same, you pay 7.5% on dividends which is effectively the income tax equivalent minus the 19% corporation tax that has already been paid.