Yesterday the Government, at last, confirmed its intention to re-introduce a second Finance Bill for 2017 after the summer recess, with all previously announced measures to be included.

Importantly, the Government has stated that its intention is that where policies were due to apply from 6 April 2017, this will still be the case.

Private Capital and Tax Disputes Partner Gary Ashford says “It looks like the introduction of the Requirement to Correct Offence will return. However, given the loss of time since the withdrawing of the provisions from the 2017 Finance Act, I would hope for a revised timetable to allow sufficient time for anyone affected to consider their position”.

The Original Finance Bill contained clauses around Employee Benefit Trusts including the taxation of loans taken out after 6 August 1999 and still unpaid as at 5 April 2019. We would now expect these provisions also to return. David Scott, Tax and Private Client Partner, says “Given the recent Rangers ruling, there may be significant activity by HMRC in the weeks and months ahead and so those looking at the 2019 deadline may well see HMRC activity much sooner”.