Originally posted by Fred Bloggs
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These schemes are highly profitable for the promoters so I can't see them letting up.
Incidentally, the risk of retrospective legislation is greatly reduced under the new Protocol (page 19) and it's extremely unlikely that there would ever be another case like BN66.
http://cdn.hm-treasury.gov.uk/2011bu...xavoidance.pdf
In particular, retrospective legislation would not be allowed just because HMRC had changed their view of the law, as they did with BN66 (page 19, point 3).
A change in HMRC’s interpretation of the law (unless prompted by a Court ruling) will not be regarded as ‘significant new information’.
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