Jonathan Peacock QC considers the anti-abuse provisions in FA 2000 under which the Revenue can eject a company from the tonnage tax regime and compares it to the traditional approach to anti-avoidance legislation
The tonnage tax regime has been in place now for a little over two years and by and large it seems to be working well. In particular the Inland Revenue appears to have been given clear political instructions that the regime is to be made to work and that an over-technical approach should not be adopted. However even this relatively laissez-faire approach has its limits and those are found primarily in FA 2000 Schedule 22 paragraph 41 which allows the Revenue to remove a company from the regime where there is an 'abuse'. Whilst...
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Jonathan Peacock QC considers the anti-abuse provisions in FA 2000 under which the Revenue can eject a company from the tonnage tax regime and compares it to the traditional approach to anti-avoidance legislation
The tonnage tax regime has been in place now for a little over two years and by and large it seems to be working well. In particular the Inland Revenue appears to have been given clear political instructions that the regime is to be made to work and that an over-technical approach should not be adopted. However even this relatively laissez-faire approach has its limits and those are found primarily in FA 2000 Schedule 22 paragraph 41 which allows the Revenue to remove a company from the regime where there is an 'abuse'. Whilst...
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