Tax update, May 2017

In this update we report on HMRC’s recently amended guidance on the General Anti-Abuse Rule, HMRC’s draft guidance on the new disguised remuneration provisions in the Income Tax (Earnings and Pensions) Act 2003, and on the recent modifications to the Finance Bill 2017.

We also comment on three recent cases involving the requirements for a valid Closure Notice and the correct forum for appealing them, a dispute against a penalty and HMRC’s associated unreasonable behaviour, and the question of what is to be considered “reasonable conduct” for a pension scheme administrator in order to avoid liability for a tax charge.