• Service: Tax, Global Indirect Tax, Global Mobility Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 1/31/2014

United Kingdom - Proposals relating to tax disputes, identifying promoters 

January 31: Consultation documents, issued by HM Revenue and Customs (HMRC), include proposals for taxpayers to make accelerated payment of tax that is in dispute or subject to enquiry and for identifying “promoters” of tax avoidance schemes.

The first consultation document―Tackling marketed tax avoidance―includes draft legislative language that would require taxpayers to settle disputed tax on receipt of a "failure notice" (i.e., that their case is on substantially the same grounds as a case that has already failed in a tribunal or court). The proposal is aimed at preventing taxpayers from using delaying tactics with respect to settlement of open cases.

A second consultation document issued by HMRC―Raising the stakes on tax avoidance―includes draft legislation that would establish how "high-risk promoters" would be identified and details the consequences for taxpayers who implement a high-risk promoter’s arrangement.

Both documents state that the new measures are to take effect from "Royal Assent" of Finance Bill 2014. Comments for the first document are due by 24 February 2014. Consultation on the second document has concluded.

Read a January 2014 report [PDF 748 KB] prepared by the KPMG member firm in the United Kingdom: Weekly Tax Matters (31 January 2014)

Also included in the report are the following topics:

  • Country-by-country reporting under BEPS: OECD discussion draft published
  • The Bridport & West Dorset Golf Club – Tax Journal article following the CJEU Judgment
  • Court of Appeal – Reed Employment Limited
  • Upper Tribunal: McCarthy & Stone
  • Southern Cross Employment Agency Limited
  • New consultation - Simplification of Intrastat
  • OTS report on expenses and benefits
  • Sleeping and inactive limited partners – Liability to make NI contributions

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