International Tax - October 2011

Flip-Flops anyone?

Surely the most annoying and pointless footwear ever invented – these rubber abominations, with their trademark whoosh and slap, as rubber hits heel, dig into the tender parts between your big toe and the one next door in ways that the architects of the Geneva Convention surely had in mind when outlawing cruel and unusual punishments. Yet, I have noticed the increasing tendency for grown men wearing flip flops around town, no matter what the weather or the season. While such crimes against fashion can be put down to innocent but misguided motives I am afraid that the same cannot be said for the government's frequent policy flip-flops on taxation.

For instance, the government announced, with many trumpets, on 1 August a "tax treaties anti-avoidance" strategy. This was designed to prevent both resident and non-residents from relying on provisions within our tax treaties to avoid UK tax (despite the fact that the whole purpose of tax treaties is to