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Whether all tax practitioners understand the scope of professional conduct?
I enjoyed reading Pete Miller’s article on liquidations and the targeted anti-avoidance rule in ITTOIA 2005 s 396B (‘Is this another wind-up?’ Taxation 3 August 2017) as well as the supplementary discussion between Pete and Andrew Hubbard. Having read the initial Readers’ Forum query and responses (‘Is this a wind-up? Taxation 6 July 2017) I was left in some doubt as to what advice was being given to ‘Naïve’ and was puzzled about the comments made in relation to the latest version of Professional Conduct in Relation to Taxation.
The reader’s query raised indirectly an area of concern often ignored by practitioners.
In my view Pete’s article analysed the tax issues properly and made clear that despite the reservations expressed in the earlier reply by Robert Maas the transactions in securities (TiS) provisions would be precluded from operating if the board of directors of a...
