Business Tax

Trade Here, Pay Here • UK Management Tax • Graduated Rates
New Business Protection • End the Expenses Game • Small Business First

The Problem

Amazon sold approximately £26 billion in the United Kingdom last year. Its UK corporation tax bill was a fraction of what a profitable British business of equivalent revenue would pay. The difference is not illegal. It is structural. Amazon routes its UK revenue through a subsidiary in Luxembourg, where the tax rate is lower. The profit is ‘earned’ in Luxembourg, not in the UK, because the corporate structure says so. The products were sold in the UK. The deliveries were made in the UK. The workers were employed in the UK. The roads, police, courts, broadband, and NHS that made the business possible are all in the UK. But the profit is in Luxembourg.

Google, Apple, Starbucks, Facebook, and hundreds of other multinational companies do the same thing. They sell to British customers, use British infrastructure, employ British workers, and pay tax somewhere else. The mechanism varies — royalty payments to subsidiaries, management fees to parent companies, intercompany loans at inflated interest rates — but the result is the same: the profit disappears before it can be taxed. The bookshop on the high street pays full corporation tax on its modest profit. The online giant that destroyed its business pays a fraction, because it can afford the accountants who know how to make profit vanish across borders.

BUILD ends this with a simple principle: trade here, pay here. If you sell goods or services to UK customers, you pay UK tax on the revenue those sales generate. We do not care where your head office is. We do not care where your holding company is registered. We care where the money was spent. It was spent here. You pay here.

You used our roads. You used our police. You used our courts. You used our NHS for your workers. You used our customers’ money. That costs us money. You pay for the privilege of operating here. No exceptions. No Luxembourg. No Ireland. Here.

Pillar 1: Graduated Corporation Tax

Small businesses pay less. Big businesses pay more. The corner shop is not taxed the same as the multinational. The rate matches the scale.

Up to £50,000 profit: 15%

The small business rate. Micro-businesses, sole traders operating through a limited company, startups past their protection period, one-person operations. Fifteen percent on the first £50,000. Lower than the current 19% small profits rate. Small businesses are the backbone of local economies. They are taxed lightly because they operate on thin margins and reinvest almost everything.

£50,001 – £250,000 profit: 20%

Growing businesses. Employing staff, investing in premises, building something. Twenty percent. Still lower than the current 25% main rate. The business is generating real profit but it is not a multinational. The rate reflects that.

£250,001 – £1,000,000 profit: 25%

Established, profitable businesses. A quarter of profit goes to the state. This is the current main rate, retained for medium-sized companies.

£1,000,001 – £10,000,000 profit: 30%

Large businesses making substantial profit. The rate steps up. The company can afford it. The contribution to the public services it depends on increases accordingly.

£10,000,000+ profit: 35%

Multinational-scale profit. Thirty-five percent. The company making £10 million+ in annual profit is using the full weight of British infrastructure — roads, ports, airports, courts, police, broadband, energy grid, NHS, education system — and its contribution reflects that. Still lower than the headline rate in many comparable economies. Still competitive. But no longer the bargain basement that the current system provides.

Pillar 2: UK Management Tax — Trade Here, Pay Here

2.1 — The Mechanism

Any company registered outside the United Kingdom that sells goods or services to UK customers pays a UK Management Tax. The tax is calculated on gross UK revenue — not profit. Revenue cannot be manipulated through intercompany charges, royalty payments, or transfer pricing. The sales happened in the UK. The revenue is visible through VAT returns, card transaction data, and customs declarations. It cannot be hidden.

2.2 — The Rate

The UK Management Tax is set at 4% of gross UK revenue. This is lower than corporation tax rates, but it is applied to revenue, not profit. For a company like Amazon, with UK revenue of £26 billion, the UK Management Tax would be approximately £1 billion. That is substantially more than Amazon currently pays in UK corporation tax, and it is uncomplicated, unmanipulable, and unavoidable.

The rate of 4% is set to be competitive enough that companies do not exit the UK market (which would harm consumers) but high enough to ensure a meaningful contribution to the infrastructure that makes their UK operations possible.

2.3 — Office in Ireland, Sales in England

The UK Management Tax applies regardless of corporate structure. A company with its European headquarters in Dublin, its holding company in Luxembourg, and its IP registered in Bermuda still pays 4% on every pound of UK revenue. The head office location is irrelevant. The board meeting location is irrelevant. The ‘principal place of business’ for tax purposes is irrelevant. The only thing that matters is: did you sell to a UK customer? If yes, you pay. The location of your brass plate does not change the location of your customer.

2.4 — Credit Against Corporation Tax

Foreign-registered companies that choose to register a UK subsidiary and pay normal UK corporation tax may credit their corporation tax payments against the UK Management Tax liability. This means: if a company pays more in UK corporation tax than it would owe under the Management Tax, it pays nothing additional. The Management Tax is a floor, not a surcharge. It catches the companies that use offshore structures to avoid paying anything meaningful. It does not double-tax companies that already pay their fair share through corporation tax.

Pillar 3: New Business Protection

3.1 — First 12 Months: Tax-Free

A newly registered UK business pays zero corporation tax in its first 12 months of trading. Nothing. The first year is for surviving, establishing, reinvesting, and finding your feet. Most businesses that fail, fail in the first 18 months. Taking tax from a business that is still working out whether it can survive is taking money it needs to reach year two.

The tax-free period begins on the date of first trading, not the date of registration. A company that registers in January and begins trading in March has its 12-month tax-free period from March. No gaming the system by registering early to extend the window.

3.2 — Months 12-24: Threshold Protection

In the second year of trading, the business pays corporation tax only on profit exceeding £50,000. If a startup makes £40,000 profit in year two, it pays nothing. If it makes £60,000, it pays 15% on the £10,000 above the threshold — £1,500. The business is still establishing. The threshold protects it while it grows. From year three onwards, the standard graduated rates apply in full.

3.3 — No Abuse

The new business protection applies once per beneficial owner. You do not close a company at month 11, open a new one, and claim another 12 months tax-free. The protection follows the person, not the company registration number. HMRC’s enforcement panels (Tax Reform Charter, Pillar 5) monitor for serial registration abuse. The penalty for gaming the startup protection is retrospective taxation of the full period at standard rates plus a 50% surcharge.

Pillar 4: End the Expenses Game

4.1 — Cap Intercompany Charges

The primary mechanism for multinational profit-shifting is intercompany charges: a UK subsidiary pays a ‘management fee’ to its parent company in a low-tax jurisdiction, a ‘royalty’ for use of the brand to a subsidiary in another low-tax jurisdiction, or ‘interest’ on a loan from a related company at an inflated rate. Each charge reduces UK profit. The profit reappears in Luxembourg, Ireland, or Bermuda, where it is taxed at a fraction of the UK rate or not at all.

BUILD will cap deductible intercompany charges at a percentage of UK revenue. Any intercompany payment — management fees, royalties, interest, service charges, or any other payment to a related entity — that exceeds the cap is not deductible for UK corporation tax purposes. The profit stays in the UK. The tax is paid in the UK. The accountant who designed the structure to move it offshore has wasted the client’s money.

4.2 — Arm’s Length Enforcement

Where intercompany charges are below the cap, they must still meet the arm’s length standard: the price charged between related companies must be the same as the price that would be charged between unrelated companies for the same service. A management fee of £500 million from a UK subsidiary to a Bermuda parent for ‘strategic oversight’ that consists of two board meetings and an email is not arm’s length. It is a fiction. HMRC’s enforcement panels will assess intercompany charges and reject those that fail the arm’s length test. The profit stays in the UK. The tax is paid in the UK.

Pillar 5: Farm Production Exempt

Restated from the Farming & Agriculture Charter (Pillar 13): all income derived from agricultural production — growing food, raising livestock, and selling produce directly from farm shops — is exempt from corporation tax, income tax, and capital gains tax. The farmer keeps what they earn. The subsidy-tax-subsidy loop is eliminated. Diversification income (B&B, glamping, events) is taxed at normal rates. The person farming the land pays nothing. The corporation collecting rent without farming pays full tax.

This exemption is a deliberate, permanent feature of the tax system, not a temporary relief. Britain’s food security depends on farms surviving. Farms survive when they keep the money they earn. Tax them and they need subsidies. Don’t tax them and the subsidies become unnecessary. The net cost to the Treasury is approximately the same. The administrative cost is dramatically lower. The farmer’s experience is dramatically better.

Pillar 6: Sole Traders and Self-Employed

Sole traders and self-employed individuals benefit from the £20,000 personal allowance established in the Tax Reform Charter. The first £20,000 of self-employed income — whether earned as a sole trader, a freelancer, or a one-person limited company — is completely tax-free. Above £20,000, the personal income tax bands apply.

Self-employed National Insurance is simplified. The current system of Class 2 and Class 4 NI contributions — which are calculated differently, paid differently, and confuse everyone including most accountants — is replaced with a single NI rate that matches the employed NI bands in the Tax Reform Charter. Same income, same NI, regardless of whether you work for someone else or for yourself. The self-employed are not penalised for being self-employed.

For gig economy workers who choose the contractor pathway (Work & Workers Charter, Pillar 5), the same personal allowance and NI structure applies. The platform they work through is responsible for providing the information needed for tax returns (total earnings, dates, fees deducted). The worker is not required to be an accountant as well as a delivery rider.

The Business Tax System BUILD Will Deliver

These six pillars create a business tax system that protects the small, taxes the large, and catches the offshore.

Small businesses pay 15% on their first £50,000 of profit. Startups pay nothing for their first year and are threshold-protected for the second. The corner shop survives. The entrepreneur gets the breathing room to build something.

Large businesses pay graduated rates up to 35% on profits above £10 million. The rate is competitive but not a giveaway. The multinational that uses British infrastructure contributes to British infrastructure.

Foreign companies that sell to UK customers but register offshore pay the UK Management Tax: 4% of gross UK revenue, unmanipulable, unavoidable. Amazon pays on what it sells here, not on what its Luxembourg subsidiary claims it earned. The expenses game — management fees, royalties, intercompany loans — is capped and arm’s-length tested. The profit stays where the sales happen.

Farms pay nothing on production income. Sole traders and the self-employed benefit from the £20,000 personal allowance. Gig workers get the information they need to file without needing an accountant.

Trade here, pay here. Register where you like. Sell to our customers and you pay our tax. No Luxembourg. No Ireland. No Bermuda. Here. That is the rule.

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BUILD UK

builduk.club

August 2026

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