‘We thought it worth posting the full letter from Bob Diamond, Barclays chief executive, to Andrew Tyrie MP, Treasury Committee chairman, regarding HMT’s blocking of two tax schemes (one on buybacks of debt). This involved a rare use of retroactive legislation ...
‘The UK’s Tax Code of conduct, to which Barclays is a signatory, requires the bank to comply with the letter and the spirit of the law. This is where it gets a bit comical, in our opinion (emphasis ours): “The important judgement from our Advisors was that other companies had used a similar treatment; that it was reasonable to assume that HMRC was aware of similar treatments; and that, because HMRC had [taken] no action to prevent those treatments, there was a clear precedent to satisfy the test of the spirit of the law.”
‘Translation: Everyone else was doing tax-advantaged debt buybacks. Why the hell are you picking on us out of everyone?! Especially after we were so nice as to tell you what we were doing so you’d know what’s up …’
Joseph Cotterill and Lisa Pollack, FT Alphaville, Financial Times
29 May 2012
‘We thought it worth posting the full letter from Bob Diamond, Barclays chief executive, to Andrew Tyrie MP, Treasury Committee chairman, regarding HMT’s blocking of two tax schemes (one on buybacks of debt). This involved a rare use of retroactive legislation ...
‘The UK’s Tax Code of conduct, to which Barclays is a signatory, requires the bank to comply with the letter and the spirit of the law. This is where it gets a bit comical, in our opinion (emphasis ours): “The important judgement from our Advisors was that other companies had used a similar treatment; that it was reasonable to assume that HMRC was aware of similar treatments; and that, because HMRC had [taken] no action to prevent those treatments, there was a clear precedent to satisfy the test of the spirit of the law.”
‘Translation: Everyone else was doing tax-advantaged debt buybacks. Why the hell are you picking on us out of everyone?! Especially after we were so nice as to tell you what we were doing so you’d know what’s up …’
Joseph Cotterill and Lisa Pollack, FT Alphaville, Financial Times
29 May 2012
