Avoiding avoidance

I would be willing to put money on the fact that everybody who has worked in the tax business dealing with clients has been asked for advice on structuring a transaction in a tax efficient way. It might be something as quick and simple as ‘Do pension contributions qualify for tax relief?’ (yes within limits). It might be very complicated such as how to merge two successful businesses taking months of careful research and perhaps incurring hundreds of thousands of pounds in professional fees.

Tax law is notoriously vague in many areas. It is not uncommon to find that the word of the law expires just at the point you or your client want it to begin to describe circumstance and consequence. Deriving the meaning of the law from decided...