HM Treasury has recently released a document aimed at large businesses detailing how it intends to develop tax policy to provide greater certainty and clarity (http://www. This is particularly relevant in light of the Government’s recent approach to the development of tax law in conjunction with business (the debt cap regime and controlled foreign company rules being key examples). Business is invited to respond to the proposals about how the UK tax system could be developed to:

  • provide certainty and stability to large businesses;
  • ensure the UK remains competitive as a place in which and from which to do business;
  • minimise distortion to commercial decision making;
  • keep compliance costs at a minimum and provide a cost effective tax administration; and
  • support UK’s competitive strengths and address market failures.

To achieve this, the Government has promised that it will, where possible:

  • consult ahead of proposed changes – including canvassing ideas about implementation costs;
  • publish draft legislation for more complex changes with sufficient time to allow interested parties to comment;
  • assess the proposed changes against the principles listed above; and
  • publish updated and consolidated Explanatory Notes reflecting the full text of the Bill after it has been amended in Parliament.

Whilst these reforms are welcome, many key changes are introduced without warning or consultation, such as Bank Payroll Tax and the Senior Accounting Officer rules, which have continued to prove problematic in implementation and achieving certainty for large taxpayers. It is to be hoped that the Government considers most changes important enough to consult on going forward.