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No To Retro Tax – Campaign Against Section 58 Finance Act 2008

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    Originally posted by Ninja View Post
    "Retrospective legislation may be defined as law making which alters the future legal consequences of past actions and events. The longstanding objections to retrospective legislation are described in Bennion on Statutory Interpretation (6th ed.) p. 291:
    “Dislike of ex post facto law is enshrined in the United States Constitution and in the constitutions of many American states, which forbid it. The true principle is that lex prospicit non respicit (law looks forward not back).
    1Retrospective legislation is ‘contrary to the general principle that legislation by which the conduct of mankind is to be regulated ought, when introduced for the first time, to deal with future acts, and ought not to change the character of past transactions carried on upon the faith of the then existing law’.
    2The basis of the principle against retrospectivity is ‘no more than simple fairness, which ought to be the basis of every legal rule’.
    3Retrospectivity is artificial, deeming a thing to be what it was not. Artificiality and make-believe are generally repugnant to law as the servant of human welfare. So it follows that the courts apply the general presumption that an enactment is not intended to have retrospective effect. As always, the power of Parliament to produce such an effect where it wishes to do so is nevertheless undoubted"
    Page 13

    "The ECtHR found, at [59], that there were no compelling grounds justifying legislative intervention while proceedings were pending. Among other factors, the financial risk adverted to by the Government could not warrant its action in substituting itself for the courts in order to settle the dispute. " Page 15

    "Although these principles emanate from decisions of the ECtHR, in my view they also accurately reflect fundamental principles of the UK’s unwritten constitution. The constitutional principle of the rule of law was expressly recognised in section 1, Constitutional Reform Act 2005. It requires, inter alia, that Parliament and the Executive recognise and respect the separation of powers and abide by the principle of legality. Although the Crown in Parliament is the sovereign legislative power, the Courts have the constitutional role of determining and enforcing legality. Thus, Parliament’s undoubted power to legislate to overrule the effect of court judgments generally ought not to take the form of retrospective legislation designed to favour the Executive in ongoing litigation in the courts brought against it by one of its citizens, unless there are compelling reasons to do so. Otherwise it is likely to offend a citizen’s sense of fair play" Page 20
    http://www.judiciary.gov.uk/wp-conte...ers-v-sswp.pdf

    The document is wide ranging and doesn't limit itself to Employment Law but also references Land Law in France, and UK Tax Law (i.e. Woolwich Building Soc in 1980s), so it shows that the principles against using retro legislation apply universally.
    Next time you correspond with your MP, you might want to reference this.

    The fight goes on!
    Very interesting reference.
    Thanks for sharing!
    Help preserve the right to be a contractor in the UK

    Comment


      love the twitters to JK, glad to see her squirming and starting to lose her calm demeanour. Its starting to get to her and good! Hope a little bit of what shes actually done may start to sink in!!!! I dont care if shes feeling harassed, how many families are now staring down the barrel of being made homeless, slightly more daunting I would imagine than a few social media posts!!!
      Last edited by smalldog; 5 July 2014, 18:07.

      Comment


        Originally posted by DotasScandal View Post
        Very interesting reference.
        Thanks for sharing!
        will definitely be quoted in the first judicial review one would think!

        Comment


          No To Retro Tax – Campaign Against Section 58 Finance Act 2008

          Originally posted by smalldog View Post
          will definitely be quoted in the first judicial review one would think!
          Why wasn't this referenced in our case during the court appeals?

          Comment


            Probably because they legislated before it went to court in the case of s58

            For all the legal arguments, this current judgement is all about the judiciary getting pissed off at the government for trying to use retrospective legislation to overturn their previous judgement.

            I wouldn't get too excited about applying this to s58. Whether it's a legal use of retrospection has already been settled by the courts.

            Comment


              Originally posted by centurian View Post
              Probably because they legislated before it went to court in the case of s58

              For all the legal arguments, this current judgement is all about the judiciary getting pissed off at the government for trying to use retrospective legislation to overturn their previous judgement.

              I wouldn't get too excited about applying this to s58. Whether it's a legal use of retrospection has already been settled by the courts.
              True, but maybe indicates the way the wind is starting to blow, and we haven't got to court yet (well, not recently).

              Comment


                Originally posted by OnYourBikeGB View Post
                True, but maybe indicates the way the wind is starting to blow, and we haven't got to court yet (well, not recently).
                But when you do get to court, the judge(s) will flat out refuse to listen to any arguments about the retrospective elements of s58. That's already been decided at the HC, CoA - and the SC rejected the appeal. Unless it gets overturned at ECHR (or by parliament repealing s58), it's settled law - it's done and dusted.

                Comment


                  Originally posted by centurian View Post
                  But when you do get to court, the judge(s) will flat out refuse to listen to any arguments about the retrospective elements of s58. That's already been decided at the HC, CoA - and the SC rejected the appeal. Unless it gets overturned at ECHR (or by parliament repealing s58), it's settled law - it's done and dusted.
                  Yes, we all know that. I was referring to your observation on the judiciary being pissed off with the politicians. We aren't going to court to fight the fact it's retrospective, we're going to court to fight it on the grounds that it still doesn't apply. IMO the judiciary being pissed off with the Government trying by whatever means to take power from them works in our favour. I hope that the bar for HMRC to establish their case will be that little bit higher as a result. But thanks anyway for keeping us right.

                  Comment


                    Originally posted by lucozade View Post
                    Remind me was that high court and it was determined that retrospection was perfectly fine?
                    Although the failed judicial review of S58 does set a precedent, each case still has to be considered on its own merits. APNs are a different set of circumstances.

                    As with S58 though, it won't be easy challenging primary legislation of Parliament.

                    Comment


                      Originally posted by BrilloPad View Post
                      But we might not even be affected?

                      I do wonder when the list of schemes affected is coming out.
                      HMRC committed to publishing the list before the finance bill receives royal assent, which should be later this month.

                      Comment

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