More challenging than the increase in the number of pages of tax law is the rate of change. In the past two years the banking sector, in particular, has been subject to a previously unimagined level of tax change. The new approach to tax making policy set out in the Tax Consultation Framework should certainly be welcomed. To make it work most effectively, there needs to be a recognition that dealing with legislative change cannot be a question of simply interpreting new rules once enacted and then dealing with their application to our particular businesses.
