Published on 12 Dec 2013 • United Kingdom |
“the announcement of many specific fixes to prevent specific types of avoidance is recognition … that the GAAR is of little practical use to prevent avoidance and that was expected.”
“In a presumably satirical move, the condoc came out on the same day as a policy document was released emphasizing the government’s desire to make the UK as attractive as possible to investment managers.”
“Oh boy … Imagine, if you will, almost every professional partnership - legal and accountancy - running round this morning panicking about the fact that every one of their fixed share partners is about to become an employee, because that is what the new rules will do if we’re not careful.”
“the amended bank code of conduct is an inappropriate way to manipulate taxpayer behaviour. Seeking to impose a form of moral barometer on a specific class of taxpayer runs completely contrary to the concept of the rule of law and sets a dangerous precedent for the future”.
“Banks will approach the well trailed toughening up of the voluntary Code … with some wariness, but the great preponderance of Banks appear to have adhered to the Code.”
“The trouble is, these new rules don’t make much sense when you get past the headlines. The news of CGT on non-resident individuals comes just 6 months after CGT was imposed on companies selling residential properties, in a legislative package designed to persuade offshore investors to hold properties directly… What is a non-resident investor to do? A sensible conclusion might be that it is all too much trouble here and that they would be better off investing elsewhere and leaving the UK – which they can do tax-free any time up until April 2015!”
“One area of notable silence in the Autumn Statement is in relation to the BEPS project and rules to address the taxation of multinationals. No doubt we will be hearing more on that in due course, but for now this is an indicator that the UK would prefer to act together with the international community and not on a unilateral basis”.
“The threat of a penalty if the follower taxpayers do not amend their returns may in some cases put undue pressure on them not to pursue their appeals and may result in them not utilising the judicial system, even where they have a good chance of success. This could be seen as a mechanism to deny them fair access to justice.”