The City of London Law Society’s Revenue Law Committee and the CIOT have responded to the consultation document Tackling marketed tax avoidance published on 24 January 2014.
The Revenue Law Committee restricted its comments to the proposals for accelerated tax payments and the draft legislation implementing them. The committee’s main criticism centered on the wide definition of ‘tax arrangements’. It pointed out that under the draft legislation arrangements are ‘tax arrangements’ broadly if obtaining a tax advantage is the main purpose or one of the main purposes of the arrangements and so could apply to an investment through an ISA. The committee therefore strongly recommended that the measures be confined to egregious tax avoidance of the type targeted by the GAAR. It suggested that this could be achieved by limiting the application of the new legislation to arrangements the main purpose of which is...
