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This week's opinion: 18 April 2024

15 April 2024 / Andrew Hubbard
Issue: 4932 / Categories: Comment & Analysis

Avoidance – times have changed for the better.

Regular readers will know that once the shortlist for the Taxation Awards has been announced, I like to write a piece giving my thoughts about what the entries say about the current state of our profession. I will still be doing that this year but there is one observation which I would like to share with you now, as it sheds an interesting light on the continuing political debate about tax avoidance.

Over the past few years, it was notable how many firms (large and small) went out of their way in their entries to stress that they did not promote avoidance schemes and that they operated within the confines of Professional Conduct in Relation to Taxation (PCRT). This year, by contrast, almost none of the entries made that point.

Does that mean that things are going backwards? Far from it. I see it as a sign that PCRT has now become so embedded in the DNA of the profession that there is no longer any need for firms to draw attention to the approach that they take: it is taken for granted. It is nearly ten years since the Treasury challenged the profession in its paper ‘Tackling tax evasion and avoidance’ (, in effect to put its house in order. I think it can now be said that that challenge has been met.

Of course, there are still schemes out there. But if we look at the latest list of named tax avoidance schemes, promoters, enablers and suppliers (, the organisations promoting them are names that most readers would struggle to recognise. A generation ago an equivalent list would have looked very different. That is a sign of just how much things have changed.

If you do one thing…

Review the updates to HMRC guidance on discovery assessments in Enquiry Manual at EM3233 (

Issue: 4932 / Categories: Comment & Analysis
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