Over recent years there has been a continued focus by Government
and HMRC on combatting artificial tax avoidance and filling in the
'gap' in expected tax revenues. In 2004, legislation was
introduced requiring promoters of tax avoidance schemes to notify
HMRC of any new arrangements which has enabled HMRC to take early
counter-action.
During this time the tax courts have found new ways to interpret
the legislation in the way 'that Government intended' or
rather would have intended if it had realised that taxpayers would
exploit a loophole.
In addition, HMRC has started to work in a smarter manner by
marshalling its human and technological resources to find funds
hidden in foreign bank accounts, seek out traders evading tax on
their business profits and to investigate the fine details of
complex schemes designed to mitigate tax, such as film finance
schemes.