I may be wrong but the legal start point for what is seen as retrospection is Dec 2008 when HMRC via the Autumn Statement said that as of this point all "schemes" (define as you will) will be subject to review. That would have been planned over the preceding 12 months at a minimum (there were plenty of signs it was coming throughout the year). The actual prosecution of that decision kicked off much later, I agree, after HMRC had started their data capture but it was a Labour-led initiative; all the Tories did was not refuse to enact something that was already well in train.
I object to the whole concept of retrospection in taxation as much as anyone, but let's at least remember who's fault it was.
I object to the whole concept of retrospection in taxation as much as anyone, but let's at least remember who's fault it was.
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