From 1 April 2015 the small profits rate will be unified with the main rate, so there will be only one Corporation Tax rate for non-ring fence profits – set at 20%.

The disappearance of the marginal rate of Corporation Tax will mean that if there is a commercial logic for separating business activities into separate companies there may no longer be a tax disadvantage to doing so.

Special attention will however still have to be paid to setting up the correct group structure to enable any trading losses to be utilised in the most effective way.