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tax notes international - Tuck School of Business - Dartmouth College

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U.K. Tax Update<br />

Buddy, Can You Spare a Dime?<br />

by Trevor Johnson<br />

Trevor Johnson, FTII, AITI, ATT, is a chartered <strong>tax</strong> adviser and a past president <strong>of</strong> the Association <strong>of</strong><br />

Taxation Technicians. However, the views expressed are entirely his own.<br />

In the words <strong>of</strong> Private Frazer <strong>of</strong> the popular British<br />

sitcom Dad’s Army, ‘‘We’re all doooomed!’’ Socalled<br />

experts are queuing up to outdo each other with<br />

prophesies <strong>of</strong> gloom and despondency. The Bank <strong>of</strong><br />

England base rate, which stood at 5 percent last September,<br />

is now at 1.5 percent. This is the lowest rate<br />

since the bank was formed in 1694, the year in which<br />

Sir Isaac Newton discovered gravity and about 80 years<br />

before the United States came into existence.<br />

The Bank’s Monetary Policy Committee meets<br />

again on February 5, when some commentators expect<br />

a further cut and predict that at some point this year it<br />

will end up at, or very close to, zero. These dramatic<br />

reductions conjure up an image <strong>of</strong> desperation; the<br />

bank is at the wheel <strong>of</strong> the British economy careering<br />

down the mountain toward the abyss, and is pumping<br />

the foot brake harder and harder because that’s all it<br />

can do.<br />

And yet as far as businesses are concerned, the base<br />

rate is meaningless as the banks are neither passing on<br />

the reductions to existing borrowers nor advancing new<br />

loans. Their point is that the London Interbank Offered<br />

Rate, the rate at which banks borrow in the London<br />

Interbank Market, is 2.7 percent for 12-month sterling.<br />

They also have become more defensive since the<br />

subprime fiasco and are trying to rebuild their capital<br />

and pr<strong>of</strong>itability, which is why they are incurring the<br />

wrath <strong>of</strong> the government and the public at large. We,<br />

the public, see the government giving our money to the<br />

banks so that they can lend it back to us — a crazy<br />

situation, but one that isn’t working as the money is<br />

sticking in the bank’s c<strong>of</strong>fers.<br />

After handing out £37 billion to the banks, the government<br />

has introduced two sets <strong>of</strong> measures to increase<br />

the banks’ liquidity and get them lending again.<br />

These include:<br />

• Guaranteeing up to 50 percent <strong>of</strong> borrowings to<br />

businesses with turnovers below £500 million and<br />

taking as security some <strong>of</strong> the banks’ ‘‘toxic’’ investments<br />

and loans.<br />

• An extension <strong>of</strong> the Small <strong>Business</strong> Finance<br />

Scheme outlined in last autumn’s prebudget report,<br />

available to businesses with a turnover <strong>of</strong> up<br />

to £25 million. This scheme will guarantee 75 percent<br />

<strong>of</strong> loans <strong>of</strong> up to £1 million over 10 years.<br />

• The establishment <strong>of</strong> a fund to allow businesses<br />

to sell debt to the government in exchange for<br />

equity. In other words, they will swap some <strong>of</strong><br />

their debt for a slice <strong>of</strong> their business. Companies<br />

with a turnover <strong>of</strong> up to £50 million will be able<br />

to gain equity <strong>of</strong> between £250,000 and £2 million.<br />

• Allowing banks to take up government insurance<br />

against their expected bad debts, but only up to 90<br />

percent <strong>of</strong> those loans.<br />

• The Bank <strong>of</strong> England buying high-quality assets<br />

from companies in all sectors in return for cash.<br />

• Restructuring last October’s bailout by allowing<br />

Northern Rock more time to repay its government<br />

loan and allowing Royal Bank <strong>of</strong> Scotland to issue<br />

ordinary shares to the government in exchange<br />

for the preference shares to reduce the<br />

dividend burden on the bank.<br />

TAX NOTES INTERNATIONAL FEBRUARY 2, 2009 • 411<br />

(C) Tax Analysts 2009. All rights reserved. Tax Analysts does not claim copyright in any public domain or third party content.

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