Revenue Law

Chair of Revenue Law Committee

Chris Bates (Norton Rose Fulbright LLP) (Chairman)
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27/06/2018 - Tax Abuse and Insolvency Discussion Document

CLLS RLC response to Tax Abuse and Insolvency Discussion Document
Download this file (CLLS RLC response to Tax Abuse and Insolvency Discussion Document - 27 06 18.pdf)

14/02/2018 - Consultation - “Taxing Gains made by non-residents on UK immovable property” - CLLS response

Revenue Law Committee's response to the HM Revenue & Customs and HM Treasury consultation document “Taxing Gains made by non-residents on UK immovable property” dated 22nd November 2017
Download this file (CLLS - Response to Consultation re Non-UK Gains - Final.pdf)

26/11/2015 - Advertisement for two new Committee members - closing date - 16th December 2015

Advertisement for two new Committee members - closing date - 16th December 2015
Download this file (Revenue Law Committee - committee advertisement - final - 26 11 15.pdf)

04/11/2014 - Response to HMRC consultation “Strengthening the Tax Avoidance Disclosure Regimes”

The consultation sought views on proposals to further strengthen Disclosure of Tax Avoidance Schemes (DOTAS) and initial thinking about how the VAT Disclosure Regime might be updated. The response looked at the issues of the financial products hallmark, impact on business, the dual purpose of DOTAS and good administration.
Download this file (20141029 Response on HMRC consultation on strengthening the tax avoidance disclosure regimes.pdf)

17/10/2014 - Response to HMT/HMRC consultation “New employee shareholding vehicle”

At Budget 2014 the government announced it would seek views on the Office of Tax Simplification’s (OTS) recommendation to introduce a new employee shareholding vehicle to make it easier for companies wishing to manage their employee share arrangements and create a market for employees’ shares. This discussion paper explored the case for change made by the OTS and the potential issues that the introduction of an employee shareholding vehicle would raise. The submission responded in detail to the specific consultation questions.
Download this file (20141009 Response to HMRC consultation on New Employee Shareholding Vehicle.pdf)

28/07/2014 - Response to HMRC consultation: Direct Recovery of Debts consultation

The consultation described a new power which will allow HMRC “to recover debts from the accounts of debtors”. The CLLS response raised two fundamental objections to the proposals: “the fact that it will be HMRC and not the Judiciary making decisions on the application of [Direct Recovery of Debts]; and “the real potential for mistakes to be made by HMRC and the adverse consequences that will have for taxpayers”.
Download this file (20140728 Revenue Law Committee response to Direct Recovery of Debts consultation.pdf)

09/06/2014 - Response to the Office of Tax Simplification competitiveness review

The OTS’s paper formed part of its project to improve further the competitiveness of the UK tax administration for businesses. The paper presented what the OTS saw as the priority areas to review; set out some initial thoughts on how the UK’s competitiveness could be improved; explained how the OTS will carry out the project and invited evidence and contributions. In its response, the CLLS raised several general concerns, including concerns about the difficulties that businesses face in interacting with the HMRC (especially those businesses which are not large enough to qualify for the appointment of a Customer Relationship Manager (“CRM”) by HMRC), and the “confusion surrounding the policy and implementation” associated with the introduction of some taxation legislation. The paper went on to make recommendations on both how certainty and the rule of law could be better safeguarded in the field of taxation, and in relation to various classes of tax including Corporation Tax, VAT, Income Tax/NIC, Stamp Duty and Stamp Duty Reserve Tax (“SDRT”), and Stamp Duty Land Tax (“SDLT”).
Download this file (20140605 Response to Office of Tax Simplification’s 'Competitiveness review - initial thoughts and call for evidence'.pdf)

03/03/2014 - Response to HMRC consultation: Tackling marketed tax avoidance

The Consultation Paper related to proposals to require individuals and companies to pay the tax in dispute during an enquiry or appeal relating to tax avoidance. The Committee’s comments were restricted to the proposals for accelerated tax payments in follower and other cases.
Download this file (20140303 Response to HMRC consultation 'Tackling marketed tax avoidance'.pdf)

10/02/2014 - Comments to HMRC on the draft Finance Bill 2014 Partnership proposals

The submission set out a number of detailed comments on the Bill, and stated generally that “Our principal concern is with the “Salaried Members” legislation. We believe that the tests are poorly drafted, leading to unsatisfactory (over-)reliance on (entirely non-binding) HMRC guidance. The guidance contained in the technical note is confused in a number of different areas, and needs to be dramatically improved.” It also expressed concern that “affected (or potentially affected) businesses have had insufficient time to prepare”, considering that the rules come into effect on 06 April 2014, and called for the rules to be deferred until 06 April 2015.
Download this file (20140210 Revenue Law Committee comments on draft Finance Bill 2014 Partnership proposals.pdf)

05/02/2014 - Comments to the House of Lords Economic Affairs Finance Bill Sub-Committee

The submission made a number of detailed comments, and stated generally that “We have extremely grave concerns about there being tax provisions which treat one form of partnership very differently to other forms of partnership (as is the result of the LLP salaried member proposals) and over the way in which these measures are being implemented, which we think are contrary to the principle of legal certainty by which the UK sets so much store in measuring its international competitiveness. We think that as currently drawn the measures go too far, and would apply in circumstances which are not offensive when tested against the professed policy behind the changes.“
Download this file (20140205 CLLS partnership submission (final).pdf)

29/08/2013 - Response to HMRC consultation: Modernising the taxation of corporate debt and derivative contracts

The Committee recently responded to the HMRC consultation “Modernising the taxation of corporate debt and derivative contracts”. The consultation formed part of a Government review of the rules governing the taxation of corporate debt (loan relationships) and derivative contracts (with the aim of redesigning them to be simpler, clearer and more resistant to tax avoidance.” The Committee agreed with the appropriateness of undertaking a significant review of the loan relationships code and provided a number of detailed comments.
Download this file (20130830 Revenue LC response to consultation document on modernising the taxation of corporate debt and derivative contracts.pdf)

15/08/2013 - 20130815 CLLS - strengthening the code of practice on Taxation for Banks of 31 May 2013.pdf

Download this file (20130815 CLLS - strengthening the code of practice on Taxation for Banks of 31 May 2013.pdf)

13/08/2013 - 20130806 Revenue Law Committee response to reform of close company loans to participators.pdf

Download this file (20130806 Revenue Law Committee response to reform of close company loans to participators.pdf)

24/07/2013 - Response to HMRC consultation: A review of two aspects of the tax rules on partnerships

Response to HMRC consultation: A review of two aspects of the tax rules on partnerships
Download this file (20130724-Response-to-HMRC-consultation-on-partnerships---a-review-of-two-as~.pdf)

26/02/2013 - Response to HMRC Tax and Procurement Discussion Document and Draft Guidance 14th

Response to HMRC Tax and Procurement Discussion Document and Draft Guidance 14th February 2013
Download this file (20130225-Tax-and-procurement-discussion-document-and-draft-guidance.pdf)

07/02/2013 - Comments on the GAAR draft legislation and guidance

Comments on the GAAR draft legislation and guidance
Download this file (CLLS-GAAR-PAPER-5-2-2013.pdf)

12/12/2012 - Response to Consultation on Implementing the UK/US FATCA Agreement

Response to Consultation on Implementing the UK/US FATCA Agreement
Download this file (image2012-11-23-145533.pdf)

15/10/2012 - Response to HMRC consultation, Lifting the Lid on Tax Avoidance Schemes

Response to HMRC consultation, Lifting the Lid on Tax Avoidance Schemes
Download this file (Lifting-the-Lid-on-Tax-Avoidance-Schemes.pdf)

15/10/2012 - Response to HMRC consultation, Foreign Currency Assets and Chargeable Gains

Response to HMRC consultation, Foreign Currency Assets and Chargeable Gains
Download this file (Foreign-currency-assets-and-chargeable-gains.pdf)

09/10/2012 - Response to HMRC consultation High-risk areas of the tax code: The Stamp Duty

Response to HMRC consultation High-risk areas of the tax code: The Stamp Duty Land Tax transfer of rights or subsale rules
Download this file (20121031-SLDT-submission.pdf)

13/09/2012 - Response to HMRC 12 June 2012 General Anti-Abuse Rule (GAAR) Consultation

Response to HMRC 12 June 2012 General Anti-Abuse Rule (GAAR) Consultation document
Download this file (20120917-Revenue-Law.pdf)

22/08/2012 - Response to HMRC consultation on Taxation of Controlling Persons

Response to HMRC consultation on Taxation of Controlling Persons
Download this file (20120821-Submission-to-HMRC-re-Taxation-of-Controlling-Persons.pdf)

10/08/2012 - Submission to Arlene McCarthy, MEP regarding European Commission’s

Submission to Arlene McCarthy, MEP regarding European Commission’s Draft Regulation on Insider Dealing and Market Manipulation
Download this file (20120823-CLLS-Reg-Law-Cttee---MAR-Compromise-Proposal-(Aug-2012).pdf)

28/05/2012 - Response to HMRC Consultation on Possible Changes to Income Tax Rules

Response to HMRC Consultation on Possible Changes to Income Tax Rules on Interest
Download this file (20120727-Response.pdf)

13/03/2012 - Revenue Law Committee letter to David Gauke MP regarding retrospective

Revenue Law Committee letter to David Gauke MP regarding retrospective legislation – debt bybacks
Download this file (20120213-Revenue-Law-Committee.pdf)

10/02/2012 - Comments on draft clauses of Finance Bill 2012 published 6 December 2011

Comments on draft clauses of Finance Bill 2012 published 6 December 2011 relating to controlled foreign company reform and "Controlled Foreign Company (CFC) - an update" published in January 2012
Download this file (20120213-Revenue-Law-Committee-response-to-CFC-consultation-(scanned-versio~.pdf)

26/09/2011 - Response to Consultation Document on Controlled Foreign Company Reform

Response to Consultation Document on Controlled Foreign Company Reform
Download this file (image2011-09-21-141852.pdf)

02/09/2011 - Response to HMT consultation on the Patent Box

Response to HMT consultation on the Patent Box
Download this file (20110905-response-to-the-patent-box-condoc-.pdf)

31/08/2011 - Response to HMRC consultation on High Risk Avoidance Schemes

Response to HMRC consultation on High Risk Avoidance Schemes
Download this file (20110831-Response-to-consultation-doc-on-high-risk-avoidance-schemes.pdf)

24/08/2011 - Response to HMRC consultation document on Capital Allowances for Fixtures

Response to HMRC consultation document on Capital Allowances for Fixtures
Download this file (20110823-Revenue-Law-Committee-response-to-consultation-document-on-capitla~.pdf)

12/07/2011 - Response to clarification of the meaning of

Response to clarification of the meaning of "beneficial owner" in the OECD Model Tax Convention (comments on OECD Discussion Draft of 29 April 2011)
Download this file (clarification-of-beneficial-owner-OECD-Model-Tax-Convention.pdf)

22/02/2011 - Comments on the Simplification Review: Capital Gains Rules for Groups

Comments on the Simplification Review: Capital Gains Rules for Groups of Companies
Download this file (20110222-Rev-Law-Cttee-comments-on-the-Simplification-Review---Capital-Gain~.pdf)

22/02/2011 - Comments on the Draft Tax Consultation Framework and Draft Protocol on Announcem

Comments on the Draft Tax Consultation Framework and Draft Protocol on Announcements Outside Scheduled Fiscal Events
Download this file (20110222-Rev-Law-fiscal-events.pdf)

22/02/2011 - Comments on Part 11A (Controlled Foreign Company (CFC) Reform) of the

Comments on Part 11A (Controlled Foreign Company (CFC) Reform) of the "Corporate Tax Reform: Delivering a More Competitive System" Document
Download this file (20110222-Rev-Law-Cttee-comments-on-Part-IIA-Controlled-Foreign-Company-cfc-~.pdf)

09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to the Bank

Comments on the Draft Legislation for Finance Bill 2011 in relation to the Bank Levy
Download this file (20110218-Rev-Law-Cttee-comments-on-the-Draft-Legislation-for-Finance-Bill-2~.pdf)

09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Foreign

Comments on the Draft Legislation for Finance Bill 2011 in relation to Foreign Branches
Download this file (20110218-Rev-Law-1.pdf)

09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Disguised

Comments on the Draft Legislation for Finance Bill 2011 in relation to Disguised Remuneration
Download this file (20110218-Rev-Law-2.pdf)

09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Controlle

Comments on the Draft Legislation for Finance Bill 2011 in relation to Controlled Foreign Companies
Download this file (20110218-Rev-Law-3.pdf)

18/10/2010 - Response to HMT/HMRC consultation on the modernisation of tax rules

Response to HMT/HMRC consultation on the modernisation of tax rules for investment trust companies
Download this file (20101018-Consultation-on-Investment-Trust-Reform.pdf)

15/10/2010 - Response to HMT discussion document

Response to HMT discussion document "Foreign Branch Taxation"
Download this file (20101015-response-to-HMT-discussion-doc-Foreign-branch-taxation.pdf)

05/10/2010 - Response to HMT Document

Response to HMT Document "Bank Levy: A Consultation"
Download this file (20101005-Revenue-Law-Cttee-response-re-Bank-Levy-Consultation.pdf)

25/05/2010 - Response to the HMT simplification review - capital gains rules for groups

Response to the HMT simplification review - capital gains rules for groups of companies
Download this file (20100617-Response-to-the-HMT-simplification-review---capital-gains-rules-fo~.pdf)

20/04/2010 - Proposals for Controlled Foreign Companies (CFC) Reform: Discussion Document

Proposals for Controlled Foreign Companies (CFC) Reform: Discussion Document
Download this file (20100517-CFC-resp-document2010-04-20-145512.pdf)

18/02/2010 - Response to HMRC Consultation re Disclosure of Tax Avoidance Schemes (DOTAS)

Response to HMRC Consultation re Disclosure of Tax Avoidance Schemes (DOTAS)
Download this file (20100218-CLLS-response-re-Disclosure-of-Tax-Avoidance-Schemes-(DOTAS).pdf)

22/01/2010 - Response to HMRC re Treatment of Dividends Paid Following Reductions of Capital

Response to HMRC re Treatment of Dividends Paid Following Reductions of Capital
Download this file (20100122-Dividends-paid-following-reductions-of-capital-(final).pdf)

02/11/2009 - Response to HMRC Consultation - A Code of Practice on Taxation for Banks

Response to HMRC Consultation - A Code of Practice on Taxation for Banks
Download this file (20090925-Code-of-Practice-for-Taxation-of-Banks-(final).pdf)

30/10/2009 - Response to HMRC Con Doc Simplifying Unallowable Purpose Tests

Response to HMRC Con Doc Simplifying Unallowable Purpose Tests
Download this file (20091030-CLLS-Revenue-Law-Cttee-response-to-HMRC-Disc-Doc-Simplifying-Unall~.pdf)

30/10/2009 - Response to HMRC Con Doc Simplifying Transactions in Securities Legislation

Response to HMRC Con Doc Simplifying Transactions in Securities Legislation
Download this file (20091030-CLLS-Revenue-Law-Cttee-response-to-HMRC-Con-Doc-Simplifying-Transa~.pdf)

12/10/2009 - Simplification Review: Capital Gains Rules for Groups of Companies

Simplification Review: Capital Gains Rules for Groups of Companies
Download this file (20090930-CLLS-Response-Letter-re-Simplification-Review---Capital-Gains-Rule~.pdf)

05/08/2009 - Response to HMRC Consultation Document:

Response to HMRC Consultation Document: "Modernising Powers, Deterrents and Safeguards: Working with Tax Agents"
Download this file (20090805-CLLS---WORKING-WITH-TAX-AGENTS-(final).pdf)

29/07/2009 - Taxation of Companies Foreign Profits

Taxation of Companies Foreign Profits
Download this file (revtaxforeignprofits.pdf)

22/06/2009 - Response to Finance Bill 2009: Taxation of the Foreign Profits of Companies:

Response to Finance Bill 2009: Taxation of the Foreign Profits of Companies: Debt Caps and International Movement of Capital Provisions
Download this file (Tax-the-Foreign-Profits-of-Companies-Debt-Cap.pdf)

11/06/2009 - Response to HM Treasury Consultation Enhancing the Competitiveness of UK Funds

Response to HM Treasury Consultation Enhancing the Competitiveness of UK Funds
Download this file (20090610-Letter-to-Sue-Harper-re-Response-to-HM-Treasury-Consultation-Enhan~.pdf)

04/03/2009 - Response re HMRC Consultation: “Taxation of the Foreign Profits of Companies:

Response re HMRC Consultation: “Taxation of the Foreign Profits of Companies: Draft Provisions”
Download this file (20090303-Response-to-HMRC-Consultation-on-Taxation-of-the-Foreign-Profits-o~.pdf)

25/02/2009 - Response to HMRC Consultation: “Principles based approach to financial products

Response to HMRC Consultation: “Principles based approach to financial products avoidance”
Download this file (20090225-Response-to-consultation-re-Principles-based-approach-to-financial~.pdf)

08/04/2008 - Response to HMRC Consultation on Principles-based approach to financial products

Response to HMRC Consultation on Principles-based approach to financial products avoidance
Download this file (20080307-Response-re-HMRC-Consultation.pdf)

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