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Some HMRC press releases are pretty anodyne, but a recent one ‘HMRC urges customers to leave tax avoidance scheme promoted by London-based firm’ (tinyurl.com/hmrcpravpro) caught my attention (see also our report). HMRC is increasingly on the front foot when it comes to avoidance, trying to dissuade people from signing up in the first place rather than dealing with the consequences of involvement years later. I wonder how effective this approach will be.
What interests me is that there are still firms promoting disguised remuneration schemes. The days of simple loan arrangements are long gone, but there seems to be no limit to the ingenuity of those who devise schemes, such as the one mentioned in the press release.
I confess – at a purely intellectual level – to a sneaking admiration for the brains who can still see potential paths through the legislation, while at the same time being surprised that, in the era of the general anti-abuse rule and the current judicial approach to avoidance, promoters still believe that such arrangements might be successful. But it is right to record that this scheme was registered under the disclosure of tax avoidance schemes regime. It was only because of the registration that HMRC could issue the press release: this is not a case of a promoter operating under the radar.
I have no idea where the disguised remuneration saga will end. There will be an interesting book to be written on all of the twists and turns when it is all over. I would quite like to write it but I am not confident that I will be around that long!
