Proposing a tax rulings system

KEY POINTS

• A UK tax ruling system could be based on best practice from other countries.
• Certainty of tax outcomes benefits HMRC and taxpayers.
• The administration could be funded by government or a levy on larger businesses.
• A lack of rulings from HMRC would discourage aggressive tax avoidance.
• New legislation would benefit from the security provided by tax rulings.
• A pilot ruling system could be introduced for the new corporate interest restriction rules.

I propose that the UK adopts a system of legally binding tax rulings to enable taxpayers to agree specific and mutually binding tax outcomes with HMRC. Starting with a proposed ‘best practice’ analysis of other tax jurisdictions that do have formal rulings systems such as Australia the UK’s arrangements could comprise the following elements.

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