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HMRC to address concerns over tax treaties measure

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HMRC are to  publish an update to last month’s ‘tax treaties anti-avoidance’ consultation in the light of concerns raised by business and tax advisers.

The department is committed to ‘fully exploring’ concerns over the policy and the scope of the measure set out in draft legislation, HMRC told Tax Journal.

‘HMRC understand the interest in this measure and the concern that it has not followed the government’s approach to tax policy making in this instance, and will publish a further update on the future of the consultation in September,' a spokesman said.

Writing in last week’s Tax Journal, Philip Baker QC warned that, in effect, any arrangements to ensure that the benefit of a tax treaty is enjoyed would fall foul of the proposed rules if they reduced or eliminated UK tax.