The Chancellor's ability to announce major tax measures in the Autumn Statement 2015 was constrained by a variety of factors:

Despite this, the Chancellor managed to make a few expected and unexpected changes. Some will affect individuals; in particular the changes to dividend taxation, where dividend tax credits will be replaced by a new tax-free allowance of £5,000, with higher rates applying to dividends in excess of that amount. This measure is being introduced to prevent dividends being extracted from companies in lieu of salary.

Realising or extracting profits by making capital gains, where the tax rates can be as low as 10%, will continue to be attractive. It is not a surprise therefore that the Chancellor is looking again at the transactions in securities rules. These are designed to prevent taxpayers being able to turn an income into a capital profit. If they apply, an income tax, rather than a capital gains tax (CGT), charge can arise.

The government also continued to restrict pension relief and will announce its long-term plans in March 2016, which could lead to fundamental changes.

What was not expected was the further tax-raising measures for residential property: an additional 3% stamp duty land tax charge will be payable on purchases of second homes, resulting in a top rate of 15%. The scope of the surcharge has been justifiably criticised. For example, it could apply where a family buys a main home in the UK but already owns a property interest outside the UK. This would catch families that are required to move to the UK because of a work relocation.

In addition, any CGT payable on sales of second homes from 2017 will be due 30 days after completion of the sale, significantly accelerating its payment date. The new apprenticeship levy, to be collected from businesses through the payroll was also unexpected.

On the corporate side, much of the emphasis continues to be on transparency and compliance. The government had announced in July 2015 that it was looking at a package of measures in this area (see News brief "Summer Budget 2015: a bit of give and take"). Large businesses will be obliged to publish details of their tax strategy and relationship with HM Revenue & Customs (HMRC).

But there have been some welcome changes to the details of the proposals; for example, details of a company's expected effective rate of tax will no longer have to be published. HMRC has acknowledged that it is a commercially sensitive issue to be obliged either to reveal the effective tax rate or the reasons for any changes to that rate. It is also sensible that the obligation to publish the tax strategy will be a board responsibility, rather than that of an individual director. However, while many companies already let stakeholders know of their approach to tax, putting this on a statutory basis is a significant change.

A balance will have to be struck between transparency and publishing information that may lead to misinformed comment, resulting in confusion, rather than clarity. The Banking Code of Conduct, which was intended to encourage good practice in banks' governance, relationship with HMRC and tax planning, will be extended outside the financial sector, although renamed as a Framework for Co-operative Compliance (see News brief "Banks' tax code of practice: complying with the spirit, not just the letter, of the law").

It is welcome that while the main focus will remain on taxpayers, behaviour obligations will also be placed on HMRC. While many of the intentions behind the framework will be shared by taxpayers, there may be nervousness in the long run.

The other measure grabbing the attention of boards is the introduction of a new corporate criminal offence of failing to take measures to prevent the facilitation of criminal tax evasion. This will cause some concern. Not because tax evasion is condoned, but rather because it extends to steps taken on behalf of corporate clients, by agents or representatives. Tax for these purposes includes both UK and non-UK tax.

There will be a defence of having reasonable procedures in place and, in practice, most companies will extend the training and systems that they have in place for the Bribery Act 2010 to cover tax evasion. They will also have to be very careful as to how they use agents or representatives and seek appropriate assurances from them. Inevitably, there will be a cost involved, both in establishing the systems and in the ongoing monitoring required to ensure compliance. There is no exemption from the offence for smaller businesses although, in practice, the standard of procedures required from them may be lower than for the large multinational groups.

Lastly, in relation to BEPS, some measures are definitely to proceed, such as those combating hybrid instruments and the changes to the patent box regime, the latter is dependent on more substantial activity in the UK (that is, more qualifying expenditure in the UK) (see "Patent box changes: Finance Bill 2016", Bulletin, Taxation, this issue). The proposals restricting the deductibility of interest are on the horizon and the subject of much comment (www.practicallaw.com/2-620-4537). It is debatable whether the UK needs such a major change when its existing transfer pricing rules, if applied fully, can have the effect in practice of restricting much of the tax planning that the public finds objectionable.

One risk is that any new restrictions on interest deductibility may need to be complicated to cater for a wide variety of commercial situations. It is already proposed that specialised regimes will apply to the financial sector and some infrastructure projects. The proposals are the subject of much detailed consultation and some hostile comment. If they are to proceed, it is hoped that their designers listen to some, if not all, of the responses to the consultation.