Tom Daltry Consultant in the Tax Group of Eversheds LLP reviews the practical impact of the so-called 'Demibourne Regulations' and HMRC guidance on the application of those Regulations
Most of us would view a system which allows for tax on one amount of income to be collected twice as being fundamentally unfair. Surely such a possibility would not exist in a mature and sophisticated tax system? However this was the potential practical consequence of the decision in Demibourne SpC 486. This article examines whether HMRC's response has adequately addressed the problem and generally what the practical impact of that response will be.
The background
Many readers will be familiar with the background but a...
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Tom Daltry Consultant in the Tax Group of Eversheds LLP reviews the practical impact of the so-called 'Demibourne Regulations' and HMRC guidance on the application of those Regulations
Most of us would view a system which allows for tax on one amount of income to be collected twice as being fundamentally unfair. Surely such a possibility would not exist in a mature and sophisticated tax system? However this was the potential practical consequence of the decision in Demibourne SpC 486. This article examines whether HMRC's response has adequately addressed the problem and generally what the practical impact of that response will be.
The background
Many readers will be familiar with the background but a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
