Chancellor Gordon Brown delivered his Budget statement on the 9 March and said it represented a better deal for work, for family and for business.The Budget was something of a ragbag of new initiatives together with the final despatch of some old reliefs which had already been emasculated in previous Budgets.

The Budget did not contain any particular theme although, as might be expected from a Labour government, it tended to benefit the lower-paid and families with children at the expense of others.

Unlike Gordon Brown's previous two Budget s, there were no structural taxation reforms.In regard to individuals, mortgage interest relief is to be withdrawn from 6 April 2000, although this relief had already become substantially devalued.

The ceiling for mortgage interest relief had remained for many years at £30,000 of borrowings and the interest itself was relievable only at a 10% rate.

At most, therefore, it was worth no more than about £200 to any taxpayer.Much the same can be said in relation to the married couples' allowance and the additional personal allowance given to some with family responsibilities.

These allowances are to be abolished for people aged younger than 65 from April 2000.Although the elderly will, at least for the time being, retain the allowance, people reaching retirement age after April 2000 will not receive the allowance.

But, in any event, in 1999/2000 the allowance is only £1,970 relieved at 10%.Although the Chancellor made much of being able to introduce a 10p starting rate of income tax, this will apply only to the first £1,500 of earned income and will replace the lower rate of 20% which presently applies to a wider band of income.

From April 2001, one year after the abolition of married couple's allowance, an allowance of £4,160, relievable at a rate of 10%, to be known as children's tax credit, will be given to families with one or more children younger than 16.

However, unlike the married couples' allowance, this credit will gradually be withdrawn where the person claiming it is liable to tax at the higher rate.

The proposed reduction in the basic rate from 23% to 22% is welcome, but this will not take effect until April 2000.With regard to business taxation, there is to be a substantial reform of the corporation tax from April of this year by the repeal of the advance corporation tax and tax credit system.

However, these changes had previously been announced.Companies paying dividends will no longer have to account for advance corporation tax, and - subject to certain transitional arrangements in relation to charities, PEPs and ISAs - no recoverable credits will be available to the recipients of dividends.

This is bound to affect harshly individuals, particularly the old, who, while having low incomes, receive dividend income in respect of which they have in the past been able to recover the attaching tax credits.Following substantial lobbying, the chancellor had indicated that he would give the matter further consideration, but announced a little time ago that the government would not be changing its mind.

These new arrangements concerning dividend income will have a knock-on prejudicial effect for discretionary trusts under the regime in sections 686 and 687 of the Taxes Act.

The trustees of a discretionary trust in receipt of UK dividends will not have available any tax credits to set off against the tax liability (34%) incurred on distributions to discretionary beneficiaries.In the interest of beneficiaries, trustees might wish to consider investment policies, but it could be difficult to switch from equities without incurring a substantial capital gains tax charge.

The Chancellor is introducing, from April 2000, a new 10% corporation tax rate.

However, this is only available to companies with taxable profits of £10,000 or less, with marginal relief being available where the taxable profits are between £10,000 and £50,000.Last year, the Chancellor reformed the basis of capital gains tax applying to individuals and trusts, and there was a subsequent consultative exercise on the taxation of company gains.

Howev er, the chancellor has decided to make no change in that regard.

Therefore, it follows that corporate capital gains will continue to be assessed on a completely different basis from individual capital gains.

Tapering relief, without indexation, is now available to individuals.

However, the rationale for introducing tapering relief for individuals is not considered appropriate for companies which will continue to enjoy indexation of their costs of acquisition.Last year saw - following publicity regarding a trust under which the then Paymaster General was said to be a beneficiary - substantial changes in the way that capital gains realised by foreign trusts were to be taxed.

This year, there are few proposed changes in relation to trusts.

The only one of general interest to practitioners concerns parental bare trusts made for the benefit of infant children.

Since the child has an indefeasibly vested interest in the income and capital of such a trust, any income arising to the trust which is not distributed is treated as the child's.

The child is able to set off the personal allowance against the income, so in most cases avoiding income tax liability altogether.

With effect from Budget day, new trust arrangements of this kind will cease to be effective, although existing trust arrangements will apparently be unaffected.The inheritance tax which, in structure, has remained unchanged since 1986, seemed a likely candidate for reform.

However, no structural changes are proposed.

There is a modest increase in the threshold and a strengthening of the provisions for administration and collection.

Interesting, however, is a proposal to counteract the recent decision of the House of Lords in the Ingram case.

Lady Ingram, the donor, created and retained for herself a rent-free lease of her freehold house and then gave away the freehold property, subject to the lease, to the donee.

The House of Lords held that the retained lease, which enabled Lady Ingram to continue to occupy the house rent-free, did not amount to a reservation of benefit in relation to her gift of the freehold interest for the purposes of the gift with reservation rules.

If the gift with reservation rules had applied, Lady Ingram would have been treated on her death as continuing to have the beneficial ownership of the freehold house.Now, in relation to gifts on or after Budget day, such arrangements will be ineffective if the gift is made within seven years after the creation of some interest, right or arrangement which entitles the donor to occupy the property.

This counteraction will only apply to land, and will also only apply where a gift is involved.

Therefore, if a person creates a lease in their favour, and then sells the reversion to that lease at market value, the legislation would apparently not apply.

It is perhaps surprising that the chancellor moved against Ingram-type arrangements as, in the experience of practitioners, they were impractical in most situations because of the prospective capital gains tax liability on the eventual disposal of the reversion.In addition to the counteraction of the Ingram case concerning land, the Budget contains a number of other important tax changes concerning land and buildings.

The chancellor has found stamp duty on land transactions an easy way of raising additional revenue.

The rates of stamp duty on transfers of all assets - excluding shares and securities - for more than £250,000 will be increased.

The new rates will be 2.5% where the price is more than £250,000 but not more than £500,000, and 3.5% where the price e xceeds £500,000.The increase will apply to transfers on or after 16 March, except for transfers made in pursuance of a contract made on or before 9 March.

The separate scales of rates of duty on rent will remain unchanged.

In the light of previous increases in stamp duty made by this chancellor, much time and effort is often spent to mitigate stamp duty liabilities otherwise arising in the course of commercial transactions.Many arrangements adopted involve the execution of documents abroad, usually under power of attorney, although these have sometimes not proved to be effective (see, for example, the Parinv case).

These off-shore stamp duty schemes often depended for their rationale on the premise that, if the document had to be brought into the UK to be stamped, this could be done within 30 days after that time without penalty.Interest will now be charged at a commercial rate on duty that is not paid within 30 days of the execution of a document, wherever execution takes place.

Therefore, the interest charge will be a substantial discouragement to the use of off-shore schemes.

Also, in relation to land, legislation will be introduced by which reverse premiums paid by landlords to induce potential tenants to take out a lease, will he chargeable to income or corporation tax.

The timing of the charge will follow accepted accountancy practice.

It is understood that generally such a reverse premium is in the accounts of the tenant spread over the period to the first rent review.

Therefore, it follows that although such premiums will now be taxed, tenants should enjoy some deferral benefit.As usual, the Budget contains a number of measures designed to attack tax avoidance.

However, it seems these measures will, in general, be specifically targeted, and it should be possible, therefore, in most cases for taxpayers to determine whether or not they are affected.

In last year's Budget the chancellor indicated that he was considering the introduction of a general anti-avoidance rule (GAAR) for direct taxes.

Subsequently, a consultative document was issued which discussed the possible introduction of a GAAR for corporate direct taxes.

Recently, Customs & Excise canvassed the possibility of a mini-GAAR for VAT on construction services.

The Law Society's revenue law committee, with others, strongly opposed the introduction of legislation of this kind because it would effectively give the relevant department an arbitrary power to decide what was unacceptable tax avoidance and create substantial uncertainty in the minds of taxpayers involved in commercial transactions.The government has decided not to proceed with a GAAR for corporate direct taxes or with a mini-GAAR for VAT on construction services, but the chancellor has indicated that legislation of this kind remains an option for the future if more targeted legislation proves ineffective.

Another proposal would give Customs the right to remove a company from a VAT group which in its view presents a risk to the Revenue.

It seems that the proposed legislation might give Customs an unfettered right in that regard, but it proposes to set out in a statement of practice the circumstances in which the power would be exercised.

Some specialist practitioners view wide statutory provisions of this kind, tempered by unappealable administrative derogation, as unsatisfactory and little better than GAAR-type legislation.The chancellor has signed up to the simplification of tax legislation.

The re-write exercise proceeds, so it is hoped the tax code will in due course be wholly re-written in simp ler more accessible language.

However, much could be done to simplify the tax structure.

Although some outdated and complex relieving provisions are swept away by this Budget, these are more than replaced by new complexities.

There will now be three rates of corporation tax, instead of two, and four main rates of income tax instead of three.

Most taxpayers will cease to be entitled to married couple's allowance, but others will retain the allowance.

The children's tax credit will not be available to all families with children, and those entitled to the allowance will receive it at a rate of 10% and not their personal income tax rate.

Fairness in taxation is to be applauded, but that laudable aim should be weighed against the cost of the consequential complexities.

The present chancellor might have that balance wrong.However, although this will be the last Budget this millennium, it seems likely that Gordon Brown will have at least two more Budget opportunities before the next general election to introduce some structural reform in the interests of a simplified and transparent taxation system.