Curiouser and curiouser

WHENEVER THE REVENUE introduces new legislation there is always a problem for taxpayers and their advisers in determining whether and to what extent the new rules apply to them. In recent years the Revenue has introduced far-reaching anti-avoidance provisions which are very complex in their structure and yet affect at least potentially many ordinary taxpayers. We have only to think of the controversy surrounding the IR35 legislation. Five years on it is clear that neither the Revenue nor the profession have reached a consensus on the limits of the legislation so what chance one might ask do ordinary taxpayers have of understanding their obligations. Another example is the introduction and implementation of the non-corporate distribution rules where even the Revenue has conceded that its own understanding of parts of this legislation is flawed.

Pre-owned assets

However the...