This paper has been written as a review of the current tax treatment of the family in the UK.

This Discussion Paper provides detailed consideration of selected existing corporate tax legislation concerning schedule A, the antiavoidance rules for companies and the rules for group relief set out in schedule 18 TA 1988.

The TLRC Committee has been considering the relationship between tax and accounting measures of business income. This paper builds on the earlier discussion paper DP2 issued in April 2002, which set out some of the general issues of principle involved in any such alignment. The government is clearly attracted to aligning the corporate tax system more closely with account, and significant legislative advances in this direction have already been achieved. As a general matter this is to be welcomed, for reasons which are examined in this paper. But an examination of the principles involved leads us to conclude that now is the time to reflect on where the limits to alignment might lie. It is with this question in mind that Graeme Macdonald and Martin have written this paper at the request of the Committee as a response to the August 2003 consultation document, Corporation Tax Reform.

In this report, the Committee has been considering the relationship between tax and accounting measures of business income. Increasingly, the courts have been prepared to accept the use of accounting standards without an overlay of specific tax rules. Year by year more legislation draws upon accounting principles and practices to define the business tax base. Where could might or should this growing relationship between tax and accounting lead? The recent developments raise fundamental questions about the appropriateness of linking the business tax system to an evolving accounting process. For example, are current accounting principles and practices consistent with the requirements of the tax system? Does the current direction of accounting evolution support the closer alignment of tax and accounting measures of business income? Will closer alignment inhibit agreement on accounting standards that would otherwise improve financial reporting?