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EU Treaty tax planning for HNWIs

How will HMRC react to the EC’s formal request that the UK amends anti-avoidance legislation?

On 6 December it was quietly announced in a Ministerial Statement released with the draft Finance Bill 2012 provisions that the UK is planning to change two key pieces of anti-avoidance legislation: the rules governing transfers of assets abroad (ITA 2007 ss 714 – 751) and the attribution of gains made by non-resident companies (TCGA 1992 s 13). Proposals will be published for consultation around the time of Budget 2012 with a view to enactment in Finance Bill 2013.

This was not an altogether surprising development. The European Commission announced in February 2011 that it had issued ‘reasoned opinions’ to the UK...

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