The recent trend for enacting wide sweeping anti-avoidance legislation, such as FA 2003 s 75A, is making it increasingly difficult for taxpayers to achieve certainty. HMRC’s new guidance on s 75A is helpful, but is only a partial solution. The uncertainty will continue unless HMRC change their policy by facilitating the giving of rulings on whether s 75A would apply to proposed transactions. Failing that, taxpayers may wish to limit the period of uncertainty by making a Langham v Veltema disclosure with a view to precluding HMRC from making an extended time limit assessment.
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