The war against promoters

Finance Act 2022 includes provisions to further tighten the noose on the approximately 20 to 30 still stealthily determined promotors of tax avoidance schemes (mostly now stationed offshore and predominately disguised renumeration schemes). The new rules further build upon the changes introduced in last year’s Finance Act designed to ‘disrupt the business model/ economics and supply chains of avoidance’ as early as possible as well as ensure early public denouncement to help taxpayers understand the risks of these schemes and steer clear – a worthy objective indeed. 

HMRC will soon be empowered to apply to wind up any insalubrious promotor vehicle (query perhaps absent sufficient due diligence) and/or seek a freezing order for the assets of a person intertwined in a scheme in order to protect the exchequer from potential dissipation of funds. In itself these moves can be applauded but one questions whether...