This week's opinion

I welcome HMRC’s decision to change their approach to the remittance basis when foreign income is used as collateral for loans brought into the UK. This is an arcane area of the law and many readers (as indeed I was) may not be familiar with detailed workings of this legislation. But what is important for all of us is the principle.

HMRC decided on 4 August 2014 to withdraw their previous practice – described as concessionary – of allowing certain sums received from loans secured by foreign income not to be treated as taxable remittances. I do not have a problem with that: HMRC have the right to revise their interpretation of the law.

But what I – and others far more versed in the intricacies of all of this – found unacceptable was that HMRC intended to apply the new interpretation to remittances that had already occurred unless taxpayers...