The CIOT comments, sent to HMRC on 27 September, on a Technical Note regarding the BPRA.
In a written statement on 18 July 2013, the Exchequer Secretary to the Treasury, David Gauke, announced that HMRC would be conducting a technical review of the BPRA legislation, with a view to making its policy purpose even clearer, so that the relief will be easier for both claimants and HMRC to operate.
This announcement was made against the background of recent DOTAS (Disclosure of Tax Avoidance Schemes) disclosures involving BPRA, which appear to contain some features aimed at exploiting the relief in ways that Parliament had not intended.
The technical note launched the announced technical review. It invited comments from interested parties on possible ways in which the policy purpose underlying BPRA might be made clearer in the relevant legislation, so that the scheme may be made simpler and more certain in its application, at the same time reducing the risks of exploitation.
Our submission and the Technical Note are available below in Adobe (PDF) format.
27 September 2013