UK international corporation tax policy after Brexit: competition and reform in a changing economy

Thesis

This thesis concerns the UK’s competitive position as a player in the world of international corporation tax, dealing in particular with the impact of Brexit within this context. The main aim of the thesis is to identify and analyse the key legal changes brought by Brexit to determine the constraints it has placed on the UK’s corporation tax policymaking ability, addressed both in general and through a specific case study on the use of tax incentives to attract investment funds to the UK.

The thesis begins by first establishing a framework for analysis which situates the project within the broader theoretical and legal contexts. It then addresses the relevant legal impacts of Brexit from an overarching perspective, and finally applies these points to the specific perspective of the case study. In addition to identifying the impact of Brexit on UK international corporation tax, these analyses are built on to make suggestions for the UK’s engagement with future tax reforms (both domestically and internationally).

The thesis makes three main conclusions. The general descriptive conclusion is that Brexit imposes novel and uncertain constraints on the UK’s corporation tax policymaking ability, specifically as a result of commitments made in the EU-UK TCA and the new subsidy regime stemming from this. The case study-specific conclusion is that the UK’s current approach to attracting investments funds may nonetheless be a success following Brexit, in light of the likely compliance of the QAHC regime with the identified constraints and the apparent future direction of EU tax law. Following all this, the main normative conclusion is that if the UK wishes to attract investment through corporation tax reform it should do so by introducing broad regimes which take advantage of the UK’s unique position, improving administration with respect to its tax system, and reforming certain tax treaties.

Authors: Lernyei, PC

• DOI: 10.5287/ora-o5va4kaxq
• Type of award: MPhil
• Level of award: Masters
• Awarding institution: University of Oxford
• Language: English
• Keywords: tax policy; tax administration; international trade; tax incentives; competition; trade; UK trade; tax; tax opportunities; Brexit; tax competition; corporate tax; policymaking; international tax; EU tax; investment funds; tax constraints; business tax; EU law; tax governance; competitiveness; tax treaties; corporation tax; EU trade; QAHC; UK tax; taxation
• Subjects: European Union--Great Britain; Corporations--Taxation--Law and legislation--European Union countries; Corporations--Taxation; Business tax--Law and legislation; Business tax--Great Britain; Competition; Taxation--Law and legislation