Metaphysics and measures

Sometimes the tax system sends us into the higher realm of metaphysics. For example in the Upper Tribunal case of David Keyl, the judge said:

"It is suggested that there could be a period between the scintilla of time before midnight and the scintilla of time after midnight, leaving the precise point of midnight as a temporal no man’s land. It left open the possibility that if something occurred at that precise point then it did not occur in the period that ended at midnight or the succeeding period that commenced from midnight.”

Elsewhere in the judgment there is an extended debate on the meaning of the word “in”. Is it any wonder that people scratch their heads in bewilderment at our tax system?

The point at issue in the case is an important one: how does the annual investment allowance work where there is a cessation on the last day of a period of account? I suspect that even some experienced advisers might have got this point wrong in practice.

If you do one thing…

Read the consultation document on large business compliance (see also the news item “Spotlight falls on large business”). The document is worth reading to understand how far HMRC are pushing the tax transparency agenda. This includes the Orwellian sounding “special measures” for companies that do not meet HMRC’s standards.

It is surely only a matter of time before similar thinking will be applied to all taxpayers.

We are moving into an environment that is very different from the one in which many of us grew up.

I am not against change – some of the proposals seem worthy of support – but I am concerned that its pace could be unsustainable.