“It’s good to see the Chancellor has listened to representations, in particular narrowing the notification requirement.
“While the devil will certainly be in the detail, this should reduce the admin burden on companies and ensure HMRC is not inundated with a wave of protective notifications.
“The Red Book also refers to new specific exclusions which helps to narrow the scope. However, it does not address the definition of substance, so the rule is still likely to create uncertainty for companies and leave too much discretion to HMRC in the way it is applied.
“Like an elephant, you know artificial diversion when you see it but it’s difficult to define in law. With today’s announcements, the Chancellor has narrowed the scope, but the fact remains that it’s still an elephant.”
Jessica Liebmann, KPMG Corporate Communications
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This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.