The figures, out last week, reveal it has received 2,000 disclosures in 25
months. The decision to make them public on a regular basis follows detailed
freedom of information requests on the numbers, from Private Eye magazine in
particular, and could be said to be a victory for greater openness in Whitehall.
The plan to get tax advisers to reveal their avoidance schemes has been a
huge success for the taxman, allowing earlier knowledge of schemes, and
undermining the economics of selling avoidance arrangements. Senior figures at
HMRC now claim that the UK is a model for other countries in relation to tax
Introduced in August 2004, the disclosure regime initially included
disclosure only on employment or financial-related products, but was widened in
2005 to the whole of income tax, corporation tax and capital gains tax after
initial disclosures tailed off. Stamp duty land tax was introduced in 2005 and
there were 485 disclosures in its first year of operation.
‘When the scheme came into effect, large numbers of disclosures came through,
then again when the scheme was extended,’ says John Cullinane, president of the
Chartered Institute of Taxation.
‘We said: “you’re having some success, but what is not being disclosed?”.
Disclosure is judgmental; if HMRC had asked for disclosures based on the
marketing of tax schemes it would have been better. They don’t want thousands of
schemes to handle anyway,’ he says.
Cullinane suggests that disclosure around inheritance tax schemes is a likely
addition to the regime in the near future.
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