This week's opinion

The temptation to say ‘I told you so’ is one I try to resist but when I can say on behalf of Taxation ‘we told you so’ I can hold back no longer.

On 19 July HMRC published ‘Interest provision legislative amendment’. It says: ‘This retrospective action clarifies the legislative framework for HMRC charging interest on unpaid tax.’ I suppose it depends on what you mean by ‘clarifies’. Rates of interest for unpaid tax are governed by FA 1989 s 178. It gives the framework but rates for individual taxes must be set by a statutory instrument appointing a day on which it takes effect. It appears that for some instruments no order was made. The clauses published on 19 July retrospectively validate those instruments. I have yet to work out the orders to which this will apply. The notice gives few details: indeed...