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If the consultation of August this year is anything to go by then this includes not just those who design, promote and market avoidance,but everyone in a so-called ‘supply chain’ who might benefit from an end user implementing avoidance arrangements.
This is clearly of relevance to lawyers, accountants, tax adviser and IFAs. Perhaps less obviously, it will also include banks, insurers, insurance brokers, trustees, company formation agents and providers of company secretarial or fiduciary services.
It is interesting that these proposals have been confirmed a matter of weeks after the main professional bodies whose members are involved in providing tax advice revised their conduct rules to essentially prevent involvement in any such planning anyway. Of course, we already have POTAS, DOTAS and GAAR.
For our full commentary on this area please see here.
We of course await the draft legislation which should be published on 5 December.
If you have any queries about these developments then please let us know