https://www.gov.uk/guidance/disguise...e-spotlight-36

Please see the above released yesterday.

Whilst HMRC might be overstating their case and the legislation may not reflect the view expressed, in a world where a Judge feels able to bring into account statements of policy and intention that are not on a statute book, the direction of travel is clear.

There are a number of arrangements out there which promise exemption from the 2019 charge. We suspect that most of them (certainly all those we've seen) will fail at the hurdle here.

Please, please be careful.

Using one of these arrangements is likely to end in litigation. We suggest therefore asking the provider of any "solution" to ensure that they have a well stocked fighting fund ready to take this on. Disappearing in 12 month's time should not be an option.