On reading the draft legislation published on 11 December intended to effectively replace the existing sub-sale relief rules it is hard to believe that the government has a tax simplification programme.
The Office of Tax Simplification an independent arm of the Treasury was set up in 2010 and is doing excellent work in endeavouring to simplify the UK’s tax system reputed to be the most complex in the world. However the draft transfer of rights legislation is so convoluted and complex that even tax lawyers are having difficulty understanding it. In the consultation meetings on the draft legislation HMRC representatives have said that it is necessary for the legislation to be so complicated because it has to incorporate an array of anti-avoidance...
