Exasperated couple surrounded by paper.

“How long do we have to keep statements from banks that don’t exist anymore?”

The magazine When Saturday Comes reports that in 2010 HMRC intensified its battle against tax avoiders in football with at least 28 winding up petitions issued to clubs.  HMRC refused to provide exact details despite a Freedom of Information request  but a spokesman said:

“As a sector football clubs have a long history of not paying their tax debts on time.  There is little HMRC can do for a business whose viability is dependent on not paying UK taxes to which they’re liable”.

Interesting article but it’s not exactly tax avoidance.  HMRC classify defaulters as won’t pay or can’t pay.  Most debts will be PAYE and NI which was never the club’s money and they will be put in the won’t pay box and hammered.

Mr Ho was a London cabbie operating out of Heathrow.  HMRC’s enquired into his 2003/4 return and:

• undertook a cash flow test
• assumed a pattern of working and
• estimated private expenses

to discredit the accounts and rebuild turnover for the year.  Based on this the officer had made discovery assessments for an additional six years.

The FTT found for Mr Ho  who was seen as “an honest, straightforward and truthful witness”.  They found the errors HMRC had used to discredit the records were acidental and insufficient to amount to negligence.  They rejected HMRC’s methods and accepted that there was no 2003/4 under-assessment.  As a result discovery assessments could not stand.

The credibility of the taxpayer was contrasted with HMRC’s behaviour.  Costs were sought by Mr Ho and the Tribunal gave a strong indication that costs would be awarded.  So straightforward mistakes can be other than negligent/careless but HMRC’s blinkers were only taken off after the expense of much time and energy.  If considering litigation a key point is the taxpayer’s credibility as a witness.  Not only what they have to say but how they say it.

This posting looks at Hankinson. The taxpayer appealed to the Upper Tribunal (UT) questioning the right in law of HMRC to make a discovery assessment. The First Tier Tribunal had determined matters of fact relating to Hankinson’s residence in the UK and these had not been appealed. The aggregate income tax and capital gains tax at stake was in excess of £30 million.

The appellant contended that before a discovery assessment is made the HMRC officer’s decision making process is twofold: has a discovery has been made and, if so would s29 prevent an assessment.

S29, described in the court’s decision as serving to “protect the taxpayer who has made an honest, complete and timely return”, imposes two conditions, either of which can protect the taxpayer from a discovery assessment: was the taxpayer either fraudulent or negligent or could the HMRC officer have been reasonably expected to be aware, based on the information provided, that further tax was due.

The UT decision was that HMRC do not have to consider whether these conditions apply: it is sufficient for an assessment to be made that the officer has discovered an insufficiency of tax. The conditions enable the taxpayer to challenge the assessment on appeal and it is then up to the Tribunal to consider them.

It will be interesting in the coming months to see how HMRC’s Schedule 36 powers will affect the discovery issue. These powers are now being using widely to look at errors in years closed against the normal enquiry route.

“a five-fold increase in criminal prosecutions to act as a deterrent to others”

HMRC’s prosecution policy has been unchanged for several years and it would be a mistake to assume that the cases that have been prosecuted will be the most serious. Certainly for several years after the introduction of the Fraudulent Evasion of Income Tax Act in 2002 many prosecutions were distinctly low level. More recently there has been a focus on organised criminal attacks on the tax system (for example MTIC and tax credit frauds) and professional advisors.

The vast majority of serious fraud cases have been and will continue to be dealt with as civil matters by HMRC under Code of Practice 9. The advantages to the taxman being:
• limited resources needed
• relatively quick turnover of cases
• early and substantial payments on account of tax due.

HMRC are evidently going to need to switch substantial resource to prosecution work to get anywhere near their five-fold increase. This could be achieved by increasing the prosecutions of minor cases but this is unlikely to prove any sort of deterrent to the COP9 type miscreant involving yields of hundreds of thousands.

Confiscation orders have been a feature of tax prosecutions for several years and a more aggressive use of the 2002 Proceeds of Crime Act could be the kind of highly cost effective approach that HMRC are looking at. In cases where there is very good evidence of tax evasion at the outset then prosecution and consequent confiscation orders will bring much more into the Treasury coffers than the typical civil settlement. In less obvious cases proceedings in the High Court for recovery orders will have the same financial effect.

A big problem with these approaches is that the guilty and their dependents are often wiped out financially. Silly me. I was forgetting the aim is “to act a deterrent to others”.

So George Osborne confirmed HMRC’s latest strategy to reduce the tax gap In last week’s 2010 Spending Review speech. A £900 million investment to “tackle tax evasion, evasion, fraud and debt” will bring in an additional £7 billion a year revenue by 2014/15. In other words another “Spend to Save” initiative to add to several others dating back to the 1990’s.

In fairness HMRC’s performance in tackling evasion and avoidance has been pretty impressive over the last few years given their staff reductions – 30% since 2004. Another 10,000 (from the current 70,000) are likely to go over the next 4 years.

Putting the additional £7 billion a year into some context HMRC’s total yield in 2008/9 from the efforts to tackle non-compliance was £12 billion. Even taking into account some of the £7 billion will relate to improved debt collection the targets are stretching - to put it mildly.

The Spending Review paper is short on detail on the way forward referring simply to:
• a five-fold increase in criminal prosecutions
• a new dedicated team of investigators to crack down on offshore evasion
• more resources to prevent tobacco and alcohol fraud; an increase in registration checks and a cyber team* to address repayment fraud
• dedicated tax experts to extend coverage of large business tackling high risk areas
• improvements in house debt collection and placing up to £1billion a year of tax debt to private sector agencies.

Offshore evasion is an obvious target given the amount and quality of information now available to HMRC and if big numbers are sought then Large Business avoidance will be in the front line. There is nothing radical here. Given HMRC’s inability over the last few years to predict with any degree of accuracy the take from various amnesties it is no surprise that observers are presently very sceptical on the taxman’s ability to delver.

Particularly intriguing is how the planned five-fold increase in prosecutions can be achieved. We will cover this in the next posting.

*Per Wikipedia
“E-, cyber-, and virtual are often used in names coined for “electronic” or computer-related counterparts of a pre-existing product or service”.

“McFedries observes that a backlash against the use of e- and cyber- can be traced to the late 1990s, quoting Hale and Scanlon requesting writers in 1999 to “resist the urge to use this vowel-as-cliché” when it comes to e- and calling cyber- “terminally overused”.

To make matters worse since April this year anyone who deliberately evades tax is at risk of the whole affair being made public via HMRC’s power to publish on their website details of “deliberate defaulters”. To qualify for this electronic equivalent of the medieval stocks, the deliberately evaded tax must be at least £25,000 and the offender must have compounded the situation by being less than co-operative in assisting HMRC with the enquiry. HMRC say they will publish the minimum amount of information for the defaulter to be identified, including business details and the amounts of tax and penalties.

Evidently HMRC wants to make people think twice before evading tax and to inculcate in the taxpaying public’s mind a common view that deliberate tax evasion is socially unacceptable. Now HMRC officers have a means of intimidating and or winding up taxpayers. Factsheet CC/FS13.

This publication is designed to help taxpayers understand the process of naming and shaming but is being issued at the start of enquiries usually before even an innocent mistake has been demonstrated by HMRC, let alone deliberate wrongdoing. So right at the start of an enquiry the threat of exposure is suspended like the sword of Damocles above the taxpayer’s head.

This approach is clearly inappropriate but I urge those getting this factsheet (or details of it) at the start of an enquiry to keep calm and carry on. For those who have made no mistakes, or whose errors are minor or non-deliberate, there is absolutely no question of being named in this way. Instead, consider responding in a polite way to any reasonable requests by HMRC, as being the surest way to close the enquiry quickly. On the other hand, if Factsheet CC/FS13 touches a nerve, maybe it is time to consult an investigations expert.

There are two critical points here. Firstly this was not a question of HMRC obtaining search warrants with a view to a criminal prosecution for tax fraud. It was simply a visit to carry out a compliance check using the powers set out in Schedule 36 FA 2008. Secondly these powers only apply where “reasonably required for the purposes of checking that person’s tax position”. There is no third party inspection power in Schedule 36 so there should be no question of a visit to an advisor to inspect a client’s documents.

Compliance checks can be carried out with notice or less commonly unannounced. HMRC can remove a “document” during a compliance check and the judge in Glenn ruled that computers were included in the extended definition of “document”. He also acknowledged that the inconvenience of having vital business equipment removed for a period of time was an inevitable consequence of the law.

Clients need to know their rights in relation to inspection visits in general and unannounced visits in particular. In relation to Glenn type problems there are two more critical points.

Whilst HMRC are allowed to make compliance checks the client is entitled to refuse entry. See CH25600. If a tribunal has approved the visit in advance then there may be a penalty to pay for refusing entry, but this is small in comparison to the benefits of having the time to take professional advice before the visit is rearranged.

If the check is underway then if the client decides not to continue with the visit:
“then you should withdraw immediately. You should offer another time to complete your work or remove the records presented for inspection and continue inspection on HMRC premises”. CH25600.

Unannounced visits will be relatively uncommon and will typically involve situations where HMRC have had problems arranging a visit or where they have reason to believe there has been tax lost. In these circumstances clients should either be on notice that:

• obstruction is likely to result in a surprise visit or

• the surprise visit is because HMRC think there is a significant problem.

I was a student in Cardiff in 1970 and was a very happy bunny when for the first time I could buy discounted LPs from the fledgling Virgin Records mail order operation. I did wonder how they managed to make any money with such keen prices and clearly Customs & Excise had similar thoughts. The scam arose from a complete accident. The 20 year old Branson drove a van to Dover bound for Calais and Customs had stamped a form PT999 confirming the records were for export and exempt from purchase tax. The sailing was then cancelled and on the drive back to London our favorite entrepreneur realized the records could be sold in the UK without purchase tax and without declaring the extra profits to the taxman.

The Transit van was soon regularly making its way to Dover and back to London with the records and the documentation for “export” to people like me sitting in a Cardiff bedsit. The sheer scale of the operation soon alerted Customs and a three week surveillance operation was mounted culminating in a raid; Branson’s arrest and a night in jail for him. Father was a barrister and a stipendiary magistrate. Customs did not prosecute but accepted a monetary settlement of a modern equivalent of some £500,000. Rather unusual for the time. Bower finishes the chapter with one of his subject’s principal credos:

“I have always enjoyed breaking the rules”.

Some good news for the low paid, although perhaps not such good news for clients who are struggling to keep afloat. Increases that have been announced to the National Minimum Wage (NMW) rates. These take effect from Friday 1 October 2010. There are different levels of NMW, depending on the age of the worker and a significant change this year is that the main rate is being extended to adults over the age of 21, instead of 22. Please remember that NMW rates apply to most adult workers who are working legally in the UK and are not ‘genuinely’ self-employed. Workers of compulsory school age are not entitled to NMW.

There is a new minimum wage rate of £2.50 per hour for apprentices, which will apply to under and over 19’s but only in the first year of their apprenticeship.

Don’t forget the regulations introduced in October 2009 in relation to tips, gratuities, service and cover charges, which can no longer count toward the National Minimum Wage. It is irrelevant how the tips etc. are paid (cash, payroll or a Tronc System).

Clients need to be reminded that since 6 April 2009 employers may incur a penalty if HMRC compliance officers discover that the employer has failed to pay the national minimum wage. The workers will be entitled to have the arrears of wages repaid at the current rates.

What is a PSA?

A PSA is a an annual agreement with HMRC whereby the employer agrees to accept the liability for certain taxable expenses payments and/or benefits in kind that would otherwise have to be:
• reported on an employees form P9D or P11D or
• included in the employees gross pay and put through the payroll.

Only certain taxable expense payments and benefits can be included in a PSA. The rules provide for the inclusion of minor items such as any taxable Long Service Awards given to employees working for the same employer. Next we have major items of expenses or benefits in kind that can be included in the PSA if they are made irregularly. For example taxable relocation costs where the allowable costs exceed the £8,000 exemption limit.

The most common type of expense payment or benefit in kind to be included will be something where it is impractical to apportion the costs between individual directors and employees. This could be the cost of a non-qualifying company party or other taxable event.

What do you need to do before submitting your client’s computations to HMRC?

This has to be done in time to meet the 19th October 2010 payment deadline.

We should start by looking at the actual P626 agreement. What has HMRC agreed can be included in the PSA? Many PSA’s include staff entertaining, staff functions, staff gifts and incentives. We then decide where the information has to come from, remembering not to overlook less obvious nominal ledger accounts, such as staff welfare. I never assume that everything posted to staff entertaining is taxable and that everything posted to meals, travel and subsistence, etc. is non-taxable.

I often find ‘staff entertaining’ meals that qualify as subsistence because they are taken away from the permanent place of work. Employees often misunderstand the rules and treat away subsistence meals as staff entertaining because one employee pays the bill for two or more employees. Another common error is treating minor and trivial costs, such as coffee and biscuits as taxable because someone pays for a group of people.

I have spotted the cost of eye tests that were to be included in the PSA but the costs are exempt and do not need to be included. Other costs that are exempt are birthday cakes or flowers for a birthday, christening, and an employee or family member in hospital. Flowers given as a reward are taxable benefit to be included in the PSA.

I always review the invoices for larger events and costs and check the number of attendees at a function to be included in the PSA. The exemption is based on the cost per attendee, not the number of employees and the exemption may apply without the client realizing that. However, I sometimes find errors where the numbers are overstated, being based on the number of employees on the payroll, not the number of attendees. I always check the number of ‘covers’ or meals booked and I check that all costs, including VAT, have been included in the calculation. We must assume that HMRC’s employer compliance officers would carry out similar checks when reviewing an employer’s procedures.

The VAT treatment of expenses payments and benefits in kind is important. The full cost must include VAT, irrespective of any VAT recovery, but our client systems usually report VAT exclusive costs. That means that we have to add VAT to the amount included in the PSA. I always use a reasonable estimate of the VAT to be added, knowing that a lot of the costs may have been incurred without VAT receipts being provided and where the VAT has not been reclaimed.

There is a statutory requirement to submit forms P9D and P11D by 6 July 2010 but there are no automatic penalties for late submission of these returns.

Interest and penalties will be charged if there is a Class 1A National Insurance Contributions liability on any taxable expense payments or benefits that are included on any late submitted P11Ds. If the returns of Class 1A NICs and Employer Declaration are received by HMRC by the 19 July 2010 Class 1A payment deadline penalties will not be automatically charged.

Providing payment of Class 1A NICs due is made by the 19 July 2010 (or 22 July for an acceptable method of electronic payment) no interest will be charged. If your client has cash flow problems and cannot pay on time then contact HMRC’s Business Support Service (0845 302 1435) and get an agreement for payment of the arrears.

If your client submitted the P11Ds and P11D (b) online last year HMRC will not have issued a paper P11D (b) this year and the employer should have received an online notification of the requirement to complete a P11D (b) return. If you are not submitting online this year and it isn’t compulsory, you can download a P11D (b) from the HMRC website to complete and submit.

‘Nil’ P11Ds are not required by HMRC but if the box on the form P35, Employer’s Annual PAYE Return was noted that P11Ds are to follow, you should contact HMRC to confirm that no P11Ds are due. If you do nothing HMRC may issue a penalty notice.

It is too late to get a P11D dispensation for 2010/11 but having just gone through the process this is a good time to apply for a dispensation for the current tax year.

Application can be made online or by post to the Employer Support Team at HMRC, Bowback House, 299 Silbury Boulevard, Witan Gate West, Milton Keynes, Buckinghamshire, MK9 1NG.

HMRC has announced a change for next year to the P46 (car) procedure reversing its decision not to accept replacement company car notifications. There are no plans to change the paper form P46 (car), but HMRC will accept electronic notifications of replacement cars from April 2011.

HMRC’s new “Advisory Fuel Rates” have been announced. These are not statutory rates. There is no compulsion to use them but they are ignored at your peril. My advice to clients is either to follow these rates or ensure that you keep good evidence of your own calculations to justify reimbursing a higher rate to employees or more importantly to satisfy an HMRC officer that you have recovered the ‘full cost’ of any private fuel.

It is important to keep accurate mileage records. Any established failure to do so will result in company car fuel scale charges being imposed by HMRC Employer Compliance Officers. I am currently advising clients where limited records were kept by the directors and employees and HMRC has been demanding tens of thousands of pounds in tax, Class 1A NICs, interest and penalties. Another common problem is where mileage records are in very rounded amounts (50, 100, 200, 300 etc.) making it difficult to prove that no private fuel was ‘enjoyed’ and where fuel scale charges would be sought.

The notional value used for calculating the fuel scale charge benefit for a company car has increased in the current tax year (2010/11) from £16,900 to £18,000. This means an increase in the lowest fuel scale charge to £1,800 for a ‘qualifying low emissions car and an increase in the highest company car fuel scale charge to £6,300. This represents payment of £210 per month income tax on the fuel benefit and £806.40 per annum Class 1A NIC. This is why it is important to avoid incurring fuel scale charges where private fuel is not intentionally provided as a perk, or where the amount of private fuel/mileage does not justify the cost. You have been warned!

Next some reminders on your client’s 2009/10 P11Ds, where the statutory deadline of 6th July 2010 is getting ever closer. Do we need to submit P11Ds at all and what box was ticked on the P35? Was it P11Ds are not due or P11Ds to follow? If we ticked the box to say that P11Ds are to follow and now find that none need be submitted, we should tell HMRC that no P11Ds are to be submitted because there is nothing to report. HMRC guidance tells us that if “HMRC has sent a form P11D(b) to you - if this occurs and you have no P11Ds to submit, tick the box in section 2 that says no P11Ds are due for the year.” Be careful to avoid a penalty notice being issued, so if in doubt write to HMRC or telephone the Employer Helpline to confirm that no P11Ds are due.

We also need to think ahead to the very important deadline for payment of the Class 1A NICs declared on form P11D(b). Payment must reach HMRC by 22 July 2010 for electronic payments, or by 19 July 2010 if your client pays by cheque.

HMRC has issued more guidance about the new Late Payment Penalties, which apply for all employers and contractors from May 2010 and HMRC is now issuing penalty warning letters. HMRC may send your client a warning letter if they do not pay on time. The guidance says that they may do this the first time in the tax year they think your PAYE payment is late. The letter is issued about two weeks after the payment date. The letter is only to let you know that HMRC think you have made a PAYE payment late and that a penalty could be charged. It is not a penalty notice and you can’t appeal against it. The obvious advice is to avoid making late payment and when a warning letter is received, pay up quickly and contact the Business Support Service (0845 302 1435) if having difficulty making payment.

From 1 June 2010 individuals no longer need to complete form P86 to tell HMRC that they have come to the UK. Employees who are not on secondment, perhaps coming to work directly for a UK employer, will have to rely on the standard P46 and you as their advisor may have to contact HMRC to obtain a proper tax code.

The late payment penalties apply also to Contractors in the Construction Industry and clients continue to have problems with penalties that are out of proportion to the offences. There may be some light at the end of the tunnel as HMRC are looking at changes to the penalties, which may make them more proportionate. This is an argument that I have been using to seek a reduction in penalties where appropriate.

Next month, I will comment on the Emergency Budget and live in hope that it will not create a lot more work for employers and contractors.

Gains may arise on various policies including UK life assurance policies but not all polices give rise to taxable gains. Where a policy gain is taxable there are a number of different events that may give rise to a gain e.g. payment at maturity of the policy, a partial surrender or for example a withdrawal in excess of 5% annual cumulative allowance.

Broadly, the gain on such an event is the difference between the amount received from the life company and the initial premium paid less any withdrawals that have been made.

Where a gain arises, even though it is referred to as a chargeable event gain, it is subject to income tax not capital gains tax. The gain is brought into charge after ‘top slicing’ relief has been applied which effectively means the gain is spread back over the number of years since the policy started or, the last chargeable event date. This slice is then added to income to discover the amount of tax payable and if only basic rate liability arises no further tax is due. If higher rate tax is due a basic rate credit of 20% of the gain is allowed against the liability.

The calculations can be complex and are explored in the article as are some of the planning areas that should be considered to defer higher rate tax liabilities or to retain the benefit of other reliefs for example tax credits.

The LibCon coalition has stated that it will seek to look at moving CGT rates on non business assets closer to income tax rates with suggestions being made by commentators that gains may be treated as being taxed at 40% for higher rate tax payers, or even being treated as the top taxable slice and being subject to 50% for those with incomes in excess of £150,000.

The biggest question being posed is when would any possible increase take effect from? The budget is set for 22 June 2010 and there is speculation that any increase would be effective from midnight but a mid-year change could lead to practical difficulties. Alternatively, any change could be made from the following 6 April 2011 giving time for taxpayers to take advantage of the current low rate of CGT. It is also not beyond the realms of possibility that any change could be made retrospectively from 6 April 2010!

It has also been suggested that the current CGT annual exemption of £10,100 could be cut to as low as £2,000 bringing many more gains within the charge to tax.

Despite this uncertainty many clients are wondering if they should sell assets now to take advantage of the 18% tax rate potentially buying them back after the 30 day period required to avoid a matching of a sale with a subsequent reacquisition. Alternatively, sales to family trusts or other family members are being considered to bank the current 18% rate. However, if there is a retrospective increase in rates, such planning will land the taxpayer with an unexpected high CGT bill!

Perhaps one should step back and look at the wider picture. CGT raises a relatively small amount of tax. The top tax ‘earners’ for the government are income tax, national insurance and VAT. With the back lash from the middle classes and within the coalition itself on the possible CGT increase we may not see a change in CGT rates at least this time round!
Difficult times; as this new government is an unknown quantity. Clients who really feel they would like to do something now, ahead of the emergency budget, need to be aware of the risks and the various opportunities that may be available to them based on their individual circumstances.

HMRC has announced a welcome reduction in the ‘Official Rate’ of interest for beneficial loans, down to 4% and effective from 6 April 2010. The additional charge for employer provided living accommodation where the cost exceeds £75,000 is also being reduced to 4% of the excess over £75,000 for 2010/11.

HMRC has produced a March 2010 CD-ROM Update to fix some problems that have arisen, including:
• the total amount of tax and NIC due sometimes being carried forward incorrectly to the 2009-10 P35
• problems transferring data from the 2009 CD-ROM
• problems opening PDF forms (Windows users only).

HMRC suggests that we install the update even if we haven’t encountered any of these problems. There is a link on the website that you can select to install the update and more guidance on what to do.

HMRC has reminded us that a new normal four-year time limit for assessments and claims kicked in from 1 April 2010 following Finance Act 2008. This affects PAYE, as well as Capital Gains Tax, Corporation Tax, Income Tax and VAT. For people outside Self Assessment, the new time limits for repayment claims don’t take effect until 1 April 2012. Their claims for 2004-05 and 2005-06 can still be made up to 31 January 2011 and 31 January 2012 respectively. The new limits from 1 April 2010 for PAYE etc are:
• Normal time limit - four years
• Careless behaviour - six years
• Deliberate behaviour - 20 years
from the end of the relevant tax period.

The new time limits are just part of HMRC’s use of new powers which it says will make the tax system more consistent and easier to understand. Its theme is supporting people who try and get their tax right, while coming down hard on those who don’t comply. Included within this are the new inaccuracy penalties and late payment penalties for PAYE, NICs, and Student Loan and CIS deductions. HMRC has published a guide to the new Late Payment Penalties on its website.

The first Budget of 2010 had a limited number of changes that will affect employers or contractors. Finance Bill 2010 will introduce powers for HMRC to require a financial security from employers with a history of serious non compliance in paying late or not paying their PAYE Income Tax. HMRC says that the measure will affect those who are determined not to pay and will not affect those who need time to pay and who make payment arrangements with HMRC.

More company car tax changes, but not until April 2012, will introduce new CO2 grams per kilometre (g/km) emissions limits. The current graduated table of Company Car Tax bands will be extended down to a new 10 per cent band and all CO2 emissions thresholds will be moved down by 5 g/km on 6 April 2012. The 10 per cent band will therefore apply to company cars with CO2 emissions up to 99 g/km. Two earlier changes, effective for five years from 6 April 2010 to 5 April 2015, will provide full relief from the chargeable benefit in kind on company cars and vans which cannot produce more than 0 gm/km CO2 engine emissions under any circumstances when driven and a second change reduces the chargeable benefit in kind on company cars which have an approved CO2 emissions figure of exactly 75 g/km or less.

A welcome relaxation will be made to the ‘available to all’ conditions applicable to childcare voucher and directly contracted childcare schemes delivered through salary sacrifice arrangements for those employees at or near the national minimum wage. The amendments will have retrospective effect for the tax year 2005-06 and subsequent tax years.

Not so welcome is the confirmation of the restriction on tax relief for workplace canteens, where salary sacrifice or flexible benefit schemes are involved. Also unwelcome to employers and employees was the confirmation of next year’s 1% increase in Class 1 NIC rates, although the new Coalition Government has now announced it will scrap the increase for employers.

The remaining employer issues include proposals for simplification of the rules on commutation of small pension pots, where somebody has to come up with something brilliant that doesn’t add to the costs of the Exchequer or HMRC and cannot be manipulated; so don’t hold your breath!
Finally, there will be some new anti-avoidance legislation covering share schemes and the use of Employee Benefit Trusts. More on these perhaps when we have a Finance Bill to digest?

As usual, interesting times.

Today’s news was full of the UK banning 500 euro notes with the expert describing the Brussels bureaucrats as “idiots” on the basis that there was never any legitimate reason for such high denominational notes which have proved a godsend to criminals and money launderers.

So we professionals get landed with a complex and time consuming reporting system whilst the law makers ensure the stable and barn doors are wide open. Now that’s what I call criminal.