TaxPersonal TaxRe: The impact of mixers on multinationals

Re: The impact of mixers on multinationals

I found Heather Self's article on the new double tax reliefs worrying.

(Re: The impact of mixers on multinationals

Firstly, her acceptance that the maze of legislation that is new s806A onwards is ‘is broadly the system we are going to have to live with’ suggests that the towel has been thrown in now even though there is still time to persuade the Revenue to change the provisions before they take effect.

The speed with which a whole new set of reliefs were introduced into the Bill before enactment leads to the suspicion that redrafting doesn’t necessarily have to take years when the opposition is firm enough.

More specifically, she highlights the exclusion from onshore pooling by new s806C of dividends from mixers which have been capped somewhere down the line.

But the effect of the exclusion appears to be broader than that. Any dividend which gives rise to so called ‘eligible unrelieved tax‘ cannot benefit from onshore pooling. That being so, it is hard to see how much relief onshore pooling can actually provide.

It seems that, by using the old technique of baffling us with drafting which appears to be designed with the intention of confusing rather than explaining, the Revenue have got away with their attack on onshore mixers by doling out a poor substitute of a relief.

Tony Brown

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