Dear Australian Taxation Office,

Are you able to please provide:

• Any correspondence you have had from the United Kingdom tax department, Her Majesty’s Revenue and Customs (HMRC), in relation to the 05 April 2019 Disguised Remuneration Loan Charge likely to impact 720+ Australian residents who worked as contractors in the UK between 1999-2019?

• Any indication from HMRC how many Australian residents will be impacted by this over and above the 720 letters they have already sent to Australians?

• Any analysis undertaken internally to understand the potential scale of the impact on Australian tax residents?

• Any justifications from HMRC for effectively retrospectively taxing legal arrangements back to 1999?

• Any justifications for taxing Australian citizens and/or residents in 2019 who have not been UK tax residents for many years and/or who are not UK tax residents on 05/04/2019?
https://www.parliament.uk/business/publi...

In addition, are you able to please provide an indication of where the Australian Tax Office stands on enforcing retroactive, or effectively retrospective, tax legislation from a foreign country?

Yours faithfully,

Jon Molyneux