Impact of UK Retrospective Tax Legislation

Jon Molyneux made this Freedom of Information request to Australian Taxation Office

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

Australian Taxation Office did not have the information requested.

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

FOI, Australian Taxation Office

1 Attachment

Dear FOI Applicant,
 
Please see attachment.
 
 
Yours faithfully,
 
FOI Team
 
 
 
 

**********************************************************************

IMPORTANT

    The information transmitted is for the use of the intended

recipient only and may contain confidential and/or legally

privileged material. Any review, re-transmission, disclosure,

dissemination or other use of, or taking of any action in

reliance upon, this information by persons or entities other

than the intended recipient is prohibited and may result in

severe penalties. If you have received this e-mail in error

please notify the Privacy Hotline of the Australian Taxation

Office, telephone 1300 661 542 and delete all copies of this

transmission together with any attachments.

*********************************************************************

hide quoted sections

FOI, Australian Taxation Office

1 Attachment

Dear FOI Applicant,
 
Please see attachment.
 

Yours faithfully,
 
FOI Team
 

 
 
 
 

**********************************************************************

IMPORTANT

    The information transmitted is for the use of the intended

recipient only and may contain confidential and/or legally

privileged material. Any review, re-transmission, disclosure,

dissemination or other use of, or taking of any action in

reliance upon, this information by persons or entities other

than the intended recipient is prohibited and may result in

severe penalties. If you have received this e-mail in error

please notify the Privacy Hotline of the Australian Taxation

Office, telephone 1300 661 542 and delete all copies of this

transmission together with any attachments.

*********************************************************************

hide quoted sections