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Correspondence from readers on topical subjects.
TAAR trouble
Under the Pre-Budget Report, the Government announced a new targeted anti-avoidance rule (TAAR) for capital losses. A general statement of principles was accompanied by draft legislation and HMRC guidance notes (the 'Original Guidance').
The Original Guidance stated that the Government's intention was that the TAAR should only catch taxpayers who 'deliberately and knowingly entered into arrangements intended to avoid tax …. [where there were] additional, complex or costly steps involved'.
Correspondence from readers on topical subjects.
TAAR trouble
Under the Pre-Budget Report the Government announced a new targeted anti-avoidance rule (TAAR) for capital losses. A general statement of principles was accompanied by draft legislation and HMRC guidance notes (the 'Original Guidance').
The Original Guidance stated that the Government's intention was that the TAAR should only catch taxpayers who 'deliberately and knowingly entered into arrangements intended to avoid tax …. [where there were] additional complex or costly steps involved'.
Most tax advisers would I think support this policy objective.
Unfortunately however the draft legislation not only fails to match the policy objective but enacts an entirely different set of rules.
Crucial to this is the use in the legislation of the phrase 'tax advantage' rather than 'tax avoidance'. As will be well known from other contexts tax advantage is...
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