Got an alternative response?

KEY POINTS

• The climate for tax avoidance.
• Aaronson: abuse rather than tax mitigation.
• Safeguards to reassure taxpayers.
• Compatibility with EU law and other tax treaties.

Another tax scheme flyer comes in from a client. What do I think? Does it work? Is it worth exploring further? What would HMRC’s reaction be?

Actually I made up that last question as I rarely come across anyone these days who thinks that HMRC will accept any arrangement that obviously saves tax without first seeking in some way to counter the perceived or actual advantage. Psychic powers are rarely needed to predict HMRC’s reaction to a ‘scheme’.

The next question the client asks or should be directed to consider is usually about how much it might cost to defend the scheme from the inevitable challenge.