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  • Pandora’s box?

    4 October 2021

    Pandora opened a box.

    I’m not sure where she got it from… or even whether it was hers… but she certainly got more than for which she bargained.

    Once opened, sickness, death and many other unspeakable evils were released into the world.

    Similarly, it seems that the ICIJ has once again got its hands on data that’s fallen off the back of a virtual lorry. Using it to unleash the unspeakable financial secrets of the wealthy and powerful.

    I don’t really have the energy to say anything about the nature of the papers – I think I covered this off with the previous data breach – the so-called Paradise Papers.

    Last time out, I defended the Queen (you’re welcome You Majesty).

    This time I feel it is Tony Blair who is getting a bit of a rough ride.

    Of course, Blair is often referred to by the frothier-mouthed political activist as a ‘war criminal’. It poses the interesting dilemma of whether it is socially less acceptable to be known as a ‘tax dodger’ or a ‘war criminal’. Tough call.

    Blair is being criticised for acquiring the shares in an offshore company which held a property that he would eventually use for his business dealings.

    By purchasing the shares rather than property he would have undoubtedly saved SDLT. This is because shares only suffer a much lower rate of 0.5% – and there is no duty AT ALL where the Company is incorporated outside of the UK.

    Of course, the dreaded ‘L’ word pops up. Wasn’t Mr Blair critical of those who exploited loopholes? But such a glaring gap in the legislation could hardly be said to be an oversight can it?

    Despite this being somewhat arbitrary (and SDLT is full of arbitrary distinctions) the system must have been designed like this.

    It is interesting to note that, many years ago, draft legislation did appear that would impose a stamp duty charge on property rich companies. But this legislation never ultimately saw the light of day.

    We now have non-resident capital gains tax (“NRCGT”) imposed on the sale of property rich company shares. Would it be so difficult to impose a corresponding SDLT charge on the ‘other side’ of the transaction.

    Certainly, the Government has shown an insatiable appetite for imposing SDLT, and more SDLT, wherever it can. For example, the recent introduction of a 2% levy for non-resident purchases.

    Apparently, once Pandora had managed to get the top back on the box she left one thing behind. That was ‘hope’.

    Can we ‘hope’ that the poring over of this kind of data will eventually lead to a simpler and / or fairer tax system?

    They say it’s the hope that kills you.

    If you have any queries about this article, offshore issues, or tax matters in general then please get in touch.

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