The last comments from me tonight to @jesse_norman.
I cannot quite believe how many criticisms I can make in response to the question from your former colleague, Dominic Grieve.
1. How on earth can you justify saying that the loan charge is "plainly" not retrospective?
I cannot quite believe how many criticisms I can make in response to the question from your former colleague, Dominic Grieve.
1. How on earth can you justify saying that the loan charge is "plainly" not retrospective?
That comment requires you to redefine "retrospective" (i.e. use HMRC's own definition).
It requires you to ignore what the ICAEW have repeatedly said since 2016: ion.icaew.com/taxfaculty/b/w…
It requires you to ignore what the ICAEW have repeatedly said since 2016: ion.icaew.com/taxfaculty/b/w…
There the ICAEW expressed concern that the then proposals were "both aggressive and retroactive" and "break the constitutional convention against retrospective legislation".
The ICAEW also noted that the proposals "contravene generally accepted notions of fairness".
The ICAEW also noted that the proposals "contravene generally accepted notions of fairness".
Even applying HMRC's definition, former tax inspector and now immediate past president of the CIOT, @Ray_McCann55 described the loan charge as "worse than retrospective legislation".
Thus, perhaps, on balance Mr Grieve is in good company and his views ought not to be surprising.
Thus, perhaps, on balance Mr Grieve is in good company and his views ought not to be surprising.
