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.
Crowe Clark Whitehill , the top 20 accountancy firm, has announced the promotion of Chris Mould to partner
The latest opinions from Accountancy Age on Making Tax Digital, and outline plans to evolve the UK's corporate governance regime
Five million taxpayers are ow using digital personal tax accounts (PTA) as part of the making tax digital strategy, HMRC said
UK-based non-doms have paid ten times more tax than the average taxpayer, raising concerns over the Brexit impact on non-dom contributions and therefore, the economy