OVER THE TOP AND TOO LATE?

摘要

These are very difficult times ahead for tax planners. On top of recent changes such as the GAAR (general anti-abuse rule), Finance Bill 2014 provides HMRC with new and very radical tools to combat the promotion of aggressive tax schemes by firms referred to by HMRC as 'high risk promoters'. These provisions will impose severe restrictions on those who continue to promote abusive tax schemes despite warnings from the government and HMRC that such activities must stop. For users of schemes the government has already made clear that it will resort to retrospective changes in tax law to defeat the continued use of tax schemes, for example as was the case in 2012 and 2013 in respect of stamp duty land tax (SDLT) schemes.