The oil industry’s trust in Mr Osborne was severely dented by his surprise raid on its profits by last year’s 12% hike in supplementary charge, coupled with a cap on relief for decommissioning. However, in this year’s Budget, the Chancellor went some way to redeem himself by agreeing to try to bind future governments to a particular rate of tax relief for decommissioning platforms and infrastructure.
There is still a long way to go with the joint initiative between HMRC, the professional bodies and tax charities to improve HMRC service delivery, but it is already starting to deliver tangible results.
Anger aroused by some of the tax measures in the Budget is symptomatic of a broader disenchantment with the government. Mr Cameron needs a more persuasive strategic narrative if he is to avoid being tripped up by the trivial.
In order for the proposed UK contractual tax transparent fund to be truly competitive, further work is needed around the stamp taxes exemptions.
HMRC has published its finalised litigation and settlement strategy and ADR guide for HMRC staff. Now we have the final version, the question is what will happen next? The immediate answer appears to be some more pilots.
The recent decision of the First-tier Tribunal in HSBC Holdings PLC and The Bank of New York Mellon Corporation v HMRC [2012] UK FTT 163 has held that the Capital Duties Directive prohibits the UK's 1.5% SDRT charge on issues or transfers of shares into an American Depository Receipt (ADR) programme, where that issue or transfer forms an integral part of the raising of capital.
By making occasional retrospective changes to its tax system the UK could be putting its reputation as a good place to do business at risk.
How independent can an employee really be?
From the perspective of an observer not close to the case, two features are difficult to understand in the recent ITC decision (Investment Trust Companies (ITCs) (In Liquidation) v HMRC [2012] EWHC 458 (Ch)).