Over the past few years, the financial sector has had to contend with a profound shift in the balance of power between taxpayer and tax authority. The change to the banking code of practice is a cause for particular alarm: what started life as a genuinely voluntary code is now effectively enforced through the threat of naming and shaming non-compliant banks. It is early days for the GAAR, but the hoped-for benefit of tax law simplification seems no closer to being realised. Looking to the future on the domestic front, it seems that HMRC’s preferred strategy is for the adoption of new powers. On the international scene, it is difficult to predict the outcome in relation to BEPS.
