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Income shifting

I must object to this draft legislation in the strongest manner.

1. The legislation is not clear too broadly drafted and reliant on HMRC guidance which does not have the force of law so cannot be relied on by the taxpayer; not very 'fair'.
2. It will increase the burden of compliance on small businesses their advisers and HMRC something the Government has repeatedly pledged it wants to reduce.
3. The only way for HMRC to enforce this will be to open thousands of enquiries into individuals' tax returns. These enquiries will rest on the Inspector and taxpayer coming to agreement on what is 'commercial'. As this is a judgment based on differing points of view it will be a different outcome every time; hardly 'fair'.
4. As these enquiries will come down to a judgment I will insist that all my clients have enquiry...