Revenue Law

Chair of Revenue Law Committee

Philip Harle Hogan Lovells LLP) (Chairman)
E-mail: philip.harle@hoganlovells.com

• 23/06/2023 - Revenue Law Committee response - stamp consultation - 22 06 23

  The CLLS Revenue Law Committee responded to HM Revenue & Customs paper: "Consultation: Stamp Taxes on Shares modernisation". The Committee's response covered the consequences of creating a single tax on securities, including impacts on such issues as payment of pension benefits, reconstruction and acquisition reliefs, and the compliance regime.

  

• 22/06/2023 - Reveneue Law Committee - Stamp duty consultation 22 06 23

  The CLLS Revenue and Company Law committees responded to the HMRC "Consultation: Stamp Taxes on Shares modernisation" on proposals relating to Stamp Duty and Stamp Duty Land Tax. They advised that a number of aspects of the current stamp duty regime are an embarrassment for solicitors to have to explain to their clients; elements of the regime are over-complex, out of date, incomprehensible and irrelevant. They called for, among other elements, a single tax on securities, adopting a single charging point, and proposals relating to the taxation of partnership, pensions, and debentures. They also offered to work with HMRC as they proceed to implement such reforms.

  

• 03/06/2021 - CLLS response - Reform of taxation of securitisation companies 03 06 21

  City of London Law Society Revenue Law Committee's Response to HM Custom and Revenue’s consultation on the Reform of Taxation of Securitisation Companies

  

• 01/06/2021 - CLLS TP Consultation 01 06 21

  City Of London Law Society Revenue Law Committee's Response To Transfer Pricing Consultation

  

• 01/06/2021 - CLLS Uncertain Tax Treatments 01 06 21

  CLLS Revenue Law Committee’s Response to HM Revenue & Customs’ consultation on Notification of Uncertain Tax Treatment by Large Businesses

  

• 15/10/2020 - CLLS response - Notification of Uncertain Tax Treatment by Large Businesses

  CLLS Response to Consultation on Notification of Uncertain Tax Treatment by Large Businesses

  

• 13/10/2020 - CLLS STS call for evidence - 13 10 20

  City of London Law Society Revenue Law Committee's Response to HMRC’s Call For Evidence in relation to the Modernisation of the Stamp Taxes on Shares Framework. Suggestions for the modernisation of the framework included rewriting the stamp duty legislation and combining stamp duty and Stamp Duty Revenue Tax into a single tax; use of electronic signatures; fixing temporary COVID measures into permanent changes; and use of smart contracts.

  

• 11/10/2019 - CLLS letter to HMRC 11 10 2019

  Response to HMRC consultation on “International Tax Enforcement: disclosable arrangements”

  

• 27/06/2018 - Tax Abuse and Insolvency Discussion Document

  CLLS RLC response to Tax Abuse and Insolvency Discussion Document

  

• 14/02/2018 - Consultation - “Taxing Gains made by non-residents on UK immovable property” - CLLS response

  Revenue Law Committee's response to the HM Revenue & Customs and HM Treasury consultation document “Taxing Gains made by non-residents on UK immovable property” dated 22nd November 2017

  

• 26/11/2015 - Advertisement for two new Committee members - closing date - 16th December 2015

  Advertisement for two new Committee members - closing date - 16th December 2015

  

• 04/11/2014 - Response to HMRC consultation “Strengthening the Tax Avoidance Disclosure Regimes”

  The consultation sought views on proposals to further strengthen Disclosure of Tax Avoidance Schemes (DOTAS) and initial thinking about how the VAT Disclosure Regime might be updated. The response looked at the issues of the financial products hallmark, impact on business, the dual purpose of DOTAS and good administration.

  

• 17/10/2014 - Response to HMT/HMRC consultation “New employee shareholding vehicle”

  At Budget 2014 the government announced it would seek views on the Office of Tax Simplification’s (OTS) recommendation to introduce a new employee shareholding vehicle to make it easier for companies wishing to manage their employee share arrangements and create a market for employees’ shares. This discussion paper explored the case for change made by the OTS and the potential issues that the introduction of an employee shareholding vehicle would raise. The submission responded in detail to the specific consultation questions.

  

• 28/07/2014 - Response to HMRC consultation: Direct Recovery of Debts consultation

  The consultation described a new power which will allow HMRC “to recover debts from the accounts of debtors”. The CLLS response raised two fundamental objections to the proposals: “the fact that it will be HMRC and not the Judiciary making decisions on the application of [Direct Recovery of Debts]; and “the real potential for mistakes to be made by HMRC and the adverse consequences that will have for taxpayers”.

  

• 03/03/2014 - Response to HMRC consultation: Tackling marketed tax avoidance

  The Consultation Paper related to proposals to require individuals and companies to pay the tax in dispute during an enquiry or appeal relating to tax avoidance. The Committee’s comments were restricted to the proposals for accelerated tax payments in follower and other cases.

  

• 10/02/2014 - Comments to HMRC on the draft Finance Bill 2014 Partnership proposals

  The submission set out a number of detailed comments on the Bill, and stated generally that “Our principal concern is with the “Salaried Members” legislation. We believe that the tests are poorly drafted, leading to unsatisfactory (over-)reliance on (entirely non-binding) HMRC guidance. The guidance contained in the technical note is confused in a number of different areas, and needs to be dramatically improved.” It also expressed concern that “affected (or potentially affected) businesses have had insufficient time to prepare”, considering that the rules come into effect on 06 April 2014, and called for the rules to be deferred until 06 April 2015.

  

• 05/02/2014 - Comments to the House of Lords Economic Affairs Finance Bill Sub-Committee

  The submission made a number of detailed comments, and stated generally that “We have extremely grave concerns about there being tax provisions which treat one form of partnership very differently to other forms of partnership (as is the result of the LLP salaried member proposals) and over the way in which these measures are being implemented, which we think are contrary to the principle of legal certainty by which the UK sets so much store in measuring its international competitiveness. We think that as currently drawn the measures go too far, and would apply in circumstances which are not offensive when tested against the professed policy behind the changes.“

  

• 29/08/2013 - Response to HMRC consultation: Modernising the taxation of corporate debt and derivative contracts

  The Committee recently responded to the HMRC consultation “Modernising the taxation of corporate debt and derivative contracts”. The consultation formed part of a Government review of the rules governing the taxation of corporate debt (loan relationships) and derivative contracts (with the aim of redesigning them to be simpler, clearer and more resistant to tax avoidance.” The Committee agreed with the appropriateness of undertaking a significant review of the loan relationships code and provided a number of detailed comments.

  

• 15/08/2013 - 20130815 CLLS - strengthening the code of practice on Taxation for Banks of 31 May 2013.pdf

  

• 13/08/2013 - 20130806 Revenue Law Committee response to reform of close company loans to participators.pdf

  

• 24/07/2013 - Response to HMRC consultation: A review of two aspects of the tax rules on partnerships

  Response to HMRC consultation: A review of two aspects of the tax rules on partnerships

  

• 26/02/2013 - Response to HMRC Tax and Procurement Discussion Document and Draft Guidance 14th

  Response to HMRC Tax and Procurement Discussion Document and Draft Guidance 14th February 2013

  

• 07/02/2013 - Comments on the GAAR draft legislation and guidance

  Comments on the GAAR draft legislation and guidance

  

• 12/12/2012 - Response to Consultation on Implementing the UK/US FATCA Agreement

  Response to Consultation on Implementing the UK/US FATCA Agreement

  

• 15/10/2012 - Response to HMRC consultation, Lifting the Lid on Tax Avoidance Schemes

  Response to HMRC consultation, Lifting the Lid on Tax Avoidance Schemes

  

• 15/10/2012 - Response to HMRC consultation, Foreign Currency Assets and Chargeable Gains

  Response to HMRC consultation, Foreign Currency Assets and Chargeable Gains

  

• 09/10/2012 - Response to HMRC consultation High-risk areas of the tax code: The Stamp Duty

  Response to HMRC consultation High-risk areas of the tax code: The Stamp Duty Land Tax transfer of rights or subsale rules

  

• 13/09/2012 - Response to HMRC 12 June 2012 General Anti-Abuse Rule (GAAR) Consultation

  Response to HMRC 12 June 2012 General Anti-Abuse Rule (GAAR) Consultation document

  

• 22/08/2012 - Response to HMRC consultation on Taxation of Controlling Persons

  Response to HMRC consultation on Taxation of Controlling Persons

  

• 10/08/2012 - Submission to Arlene McCarthy, MEP regarding European Commission’s

  Submission to Arlene McCarthy, MEP regarding European Commission’s Draft Regulation on Insider Dealing and Market Manipulation

  

• 28/05/2012 - Response to HMRC Consultation on Possible Changes to Income Tax Rules

  Response to HMRC Consultation on Possible Changes to Income Tax Rules on Interest

  

• 13/03/2012 - Revenue Law Committee letter to David Gauke MP regarding retrospective

  Revenue Law Committee letter to David Gauke MP regarding retrospective legislation – debt bybacks

  

• 10/02/2012 - Comments on draft clauses of Finance Bill 2012 published 6 December 2011

  Comments on draft clauses of Finance Bill 2012 published 6 December 2011 relating to controlled foreign company reform and "Controlled Foreign Company (CFC) - an update" published in January 2012

  

• 26/09/2011 - Response to Consultation Document on Controlled Foreign Company Reform

  Response to Consultation Document on Controlled Foreign Company Reform

  

• 02/09/2011 - Response to HMT consultation on the Patent Box

  Response to HMT consultation on the Patent Box

  

• 31/08/2011 - Response to HMRC consultation on High Risk Avoidance Schemes

  Response to HMRC consultation on High Risk Avoidance Schemes

  

• 24/08/2011 - Response to HMRC consultation document on Capital Allowances for Fixtures

  Response to HMRC consultation document on Capital Allowances for Fixtures

  

• 12/07/2011 - Response to clarification of the meaning of

  Response to clarification of the meaning of "beneficial owner" in the OECD Model Tax Convention (comments on OECD Discussion Draft of 29 April 2011)

  

• 22/02/2011 - Comments on the Simplification Review: Capital Gains Rules for Groups

  Comments on the Simplification Review: Capital Gains Rules for Groups of Companies

  

• 22/02/2011 - Comments on the Draft Tax Consultation Framework and Draft Protocol on Announcem

  Comments on the Draft Tax Consultation Framework and Draft Protocol on Announcements Outside Scheduled Fiscal Events

  

• 22/02/2011 - Comments on Part 11A (Controlled Foreign Company (CFC) Reform) of the

  Comments on Part 11A (Controlled Foreign Company (CFC) Reform) of the "Corporate Tax Reform: Delivering a More Competitive System" Document

  

• 09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to the Bank

  Comments on the Draft Legislation for Finance Bill 2011 in relation to the Bank Levy

  

• 09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Foreign

  Comments on the Draft Legislation for Finance Bill 2011 in relation to Foreign Branches

  

• 09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Disguised

  Comments on the Draft Legislation for Finance Bill 2011 in relation to Disguised Remuneration

  

• 09/02/2011 - Comments on the Draft Legislation for Finance Bill 2011 in relation to Controlle

  Comments on the Draft Legislation for Finance Bill 2011 in relation to Controlled Foreign Companies

  

• 18/10/2010 - Response to HMT/HMRC consultation on the modernisation of tax rules

  Response to HMT/HMRC consultation on the modernisation of tax rules for investment trust companies

  

• 15/10/2010 - Response to HMT discussion document

  Response to HMT discussion document "Foreign Branch Taxation"

  

• 05/10/2010 - Response to HMT Document

  Response to HMT Document "Bank Levy: A Consultation"

  

• 25/05/2010 - Response to the HMT simplification review - capital gains rules for groups

  Response to the HMT simplification review - capital gains rules for groups of companies

  

• 20/04/2010 - Proposals for Controlled Foreign Companies (CFC) Reform: Discussion Document

  Proposals for Controlled Foreign Companies (CFC) Reform: Discussion Document

  

• 18/02/2010 - Response to HMRC Consultation re Disclosure of Tax Avoidance Schemes (DOTAS)

  Response to HMRC Consultation re Disclosure of Tax Avoidance Schemes (DOTAS)

  

• 22/01/2010 - Response to HMRC re Treatment of Dividends Paid Following Reductions of Capital

  Response to HMRC re Treatment of Dividends Paid Following Reductions of Capital

  

• 02/11/2009 - Response to HMRC Consultation - A Code of Practice on Taxation for Banks

  Response to HMRC Consultation - A Code of Practice on Taxation for Banks

  

• 30/10/2009 - Response to HMRC Con Doc Simplifying Unallowable Purpose Tests

  Response to HMRC Con Doc Simplifying Unallowable Purpose Tests

  

• 30/10/2009 - Response to HMRC Con Doc Simplifying Transactions in Securities Legislation

  Response to HMRC Con Doc Simplifying Transactions in Securities Legislation

  

• 12/10/2009 - Simplification Review: Capital Gains Rules for Groups of Companies

  Simplification Review: Capital Gains Rules for Groups of Companies

  

• 05/08/2009 - Response to HMRC Consultation Document:

  Response to HMRC Consultation Document: "Modernising Powers, Deterrents and Safeguards: Working with Tax Agents"

  

• 29/07/2009 - Taxation of Companies Foreign Profits

  Taxation of Companies Foreign Profits

  

• 22/06/2009 - Response to Finance Bill 2009: Taxation of the Foreign Profits of Companies:

  Response to Finance Bill 2009: Taxation of the Foreign Profits of Companies: Debt Caps and International Movement of Capital Provisions

  

• 11/06/2009 - Response to HM Treasury Consultation Enhancing the Competitiveness of UK Funds

  Response to HM Treasury Consultation Enhancing the Competitiveness of UK Funds

  

• 04/03/2009 - Response re HMRC Consultation: “Taxation of the Foreign Profits of Companies:

  Response re HMRC Consultation: “Taxation of the Foreign Profits of Companies: Draft Provisions”

  

• 25/02/2009 - Response to HMRC Consultation: “Principles based approach to financial products

  Response to HMRC Consultation: “Principles based approach to financial products avoidance”

  

• 08/04/2008 - Response to HMRC Consultation on Principles-based approach to financial products

  Response to HMRC Consultation on Principles-based approach to financial products avoidance