Tax avoidance is a long-term structural issue. While the tools deployed by all involved have changed over time, the fundamental principle that taxes, and their administration, exist for the public good.
ACCA’s detailed response to the consultation questions are set out in the attached Appendix. However, to emphasise our position we have written a separate document which summarises our position under four headings:
- Working in the public interest
- Long-term approach
- Tax certainty
- Regulatory burden
ACCA supports HMRC in its stated aim to tackle avoidance and ensure that taxpayers do not take an unfair advantage from inconsistencies and ambiguities in tax law.
However, we are concerned that the measures proposed in the consultation document, in interaction with the cumulative impact of successive measures, presents a threat to the wider economy as the risks to advisers of commenting on any commercial activity with tax implications increase.
In addition, we are concerned that the costs of implementing such proposals would exceed the benefits, and there would be a number of adverse and unintended consequences.
We urge HMRC to adopt a more constructive and encouraging approach to all taxpayers which, we believe, would yield greater positive results in the long term, including outcomes relating to trust, cooperation and fairness.