The Tackling Tax Avoidance strategy document is a useful summary of how HMRC are trying to strangle tax avoidance at birth and if that does not work how it will hunt down avoiders and ultimately put them through costly litigation. The new developments in the strategy have been widely reported including requiring upfront payment of tax in some instances and for scheme promoters to hand over their client lists. Any pressure on the cash flow advantages from schemes is likely to be a serious deterrent.
HMRC have achieved significant behavioural shifts in recent years ably abetted by a string of Tribunal judgments that have held against taxpayers whose arrangements were held to be non-commercial and entirely tax-motivated. HMRC’s ‘Spotlights’ on marketed tax planning have helped discourage others from entering the fray at all.
Organisationally HMRC have seemed obsessed by avoidance. But tax avoidance according to HMRC’s...
