This is the last of three articles in which we will look at the potential tax consequences of a VIMBO* transaction. Whilst the mechanics of implementing such a transaction will necessarily be touched upon, the intention is more to highlight the tax questions which are likely to be encountered. We have already considered the implications on the vendor and the purchaser; this article looks at the corporate perspective.

George Osborne, the Chancellor of the Exchequer, made his first “scheduled” Budget statement last month. Below are some of the main points raised:

• The main rate of corporation tax has been reduced to 26% in 2011, an additional 1% decrease on what had been expected. The rate will be reduced by 1% per annum until it reaches 23% in 2014.
• Small Companies Rate has been reduced to 20% as expected.
• R&D credits that can be claimed as an allowable deduction have been increased to 200% with effect from 2011/12, increasing to 225% in 2012/13.
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