Originally posted by lowpaidworker
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I suspect the review will be by Govt. rather than fully independent (hope I am wrong) but even if it is I think this time it wont be a whitewash but rather compromise / changes will be made to satisfy MPs. There is little chance LC is made prospective from announcement (2016) or effect (2017), also little chance of tax rate been reduced to 10-20% for individuals or that LC is dropped altogether. Even the HOL report did not recommend any of this. Treasury senior civil servants and HMRC will resist that very strongly.
Changes could include removing closed years or applying LC from the point the DR legislation was effective (April 6 2011) as this is the point HMRC started communicating heavily that these schemes did not work.
Closed years is the most obvious compromise as many MPs, HOL, Treasury Select Committee and tax organisations (and former HMRC) have objected to this as it breaches time limits laid down by parliament but even then the devil will be in the detail. Will you have to prove you disclosed all info for closed years at the time to be out of scope? What does disclosure mean? How can you prove this for very old years (i.e. 2000, 2006)? Who has tax returns / tax records from 10-20 years ago to prove this cause HMRC certainly do not.
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