Anti-avoidance legislation is usually complex and intentionally widely drawn to ensure maximum coverage, particularly where HMRC believes that a taxpayer (or their adviser) is deliberately seeking to avoid tax or circumvent the intentions of parliament in the drafting of the legislation.
By its nature, the anti-avoidance legislation is often written deliberately subjectively, making its application one of the most difficult areas of UK tax law.
Using our vast knowledge of the legislation, understanding of jurisprudence and experience of HMRC’s own interpretation and practice, we can confidently advise on the application of this legislation and the level of risk a client is exposed to.
Jerroms Miller can assist in a variety of ways, with particular experience in Transactions in Securities (TiS), Targeted Anti- avoidance Rules (TAAR) (anti-phoenixing) and disguised remuneration.
We can help before clients enter into a transaction, we can review existing arrangements and, of course, we can assist clients with HMRC enquiries in these areas.