Reserved Corporation tax, CGT and IHT all generate lower revenues per head in Scotland

Scotland generates significantly less corporation tax per head than the UK average, simply due to lower taxable profits being generated in Scotland.

It should be noted that the apportionment of corporation tax revenues (as well as VAT) in GERS has nothing to do with where corporate headquarters are located - the GERS report is very clear on this:

Corporation tax on trading profits is estimated on a company-by-company basis, depending on the economic activity each company has in Scotland, not simply on the location of company headquarters. VAT, and other taxes such as those related to insurance activity, are related to expenditure, and are therefore estimated based on expenditure that occurs in Scotland, rather than the location of a company’s head office. - GERS FAQs

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