"The rhetorical condemnation of international businesses that arrange their affairs with an eye on the tax position - and implicit criticism of the benign tax regimes in other jurisdictions - sits uncomfortably alongside with the Government's aspiration for the UK tax system to be attractive as possible to international business."
"The extent of the proposed "TAARs" was interesting, having regard to the introduction of the GAAR. It rather suggests that the GAAR is envisaged as being used (as intended) to target abuse, whilst TAARs will continue to target avoidance. This can be interpreted very positively. Not much hope for those of us who wanted less tax legislation though!"
"It will be interesting to see how many cases are authorised for counteraction. This will demonstrate whether HMRC consider that the GAAR is a "broad spectrum antibiotic" or, alternatively, is a measure focussed on counteracting only the most egregious examples of abusive structures."
"While HMRC grouped these changes under an anti-avoidance heading, they would appear at least in part to have an element of revenue-raising, and will need to be considered in any commercially-driven M&A transaction where the target has unrealised losses."
"On the downside, as a rule of law vigilante I despair at another deployment of retrospective legislation, this time against SDLT sub-sale schemes. It really doesn't make it alright that they announced that they might do it. Doubly so when the schemes in question existed prior to that announcement and could easily have been stopped prospectively if they'd done their job properly last year. Not good enough on so many counts."
"The government made a commitment in 2010 to a new framework for making better tax law and that is now starting to show fruit. The statutory residence test and the GAAR have both benefitted from a long gestation period and, although neither will be perfect, they are a lot better than they might otherwise have been."
"counter to the trend in other parts of Europe to introduce financial transaction taxes (FTTs) ... The UK voted against the EU FTT proposal, so it is consistent with its stance on FTTs that it is constructively re-examining its own stamp taxes".
"I must be unwell. I have a small amount of sympathy for HMRC. It makes me feel uncomfortable."
"We need to know as soon as possible which areas are likely to be under review in the proposals to modernise the loan relationships and derivatives regime. Business - including the international investors which the Government is so keen to attract - need certainty around their post-tax finance and hedging strategies."
""The package of measures amending HMRC-approved plans and EMI options, previously announced, together with the raft of new measures described yesterday will mean that, taken together, we shall – when eventually all such changes take effect - have the most attractive, and flexible regime for enabling independent companies, particularly private and unquoted companies, to encourage their employees to acquire ‘own company’ shares in a tax-efficient manner."
"The Government supports employee ownership as a business model and welcomes work by the Implementation Group on Employee Ownership to take forward the recommendations of the Nuttall Review. In order to further incentivise growth of the sector, the Government is providing £50 million annually from 2014-15. This will be used to respond to recommendations from the Nuttall Review and other relevant organisations who aim to encourage employee ownership. It will also be used to fund the introduction of a capital gains tax relief on the sale of a controlling interest in a business into an employee ownership structure. Consultation on this measure will take into account the progress of work by the Department for Business, Innovation and Skills and the Implementation Group to develop an ‘off the shelf’ employee owned company model, with the intention that the new capital gains tax relief will be introduced in Finance Bill 2014. The Government will also look at further incentives in this area, including measures targeted at employees through indirect ownership models."