The position of relatively low tax UK aims to reduce reliance on taxpayer offshore mechanisms to minimize the tax burden, as well as resistance to this from the tax authorities, allowing them to apply "Through taxation" of income of foreign companies. David Kilshou, of KPMG, said that if the IRS will be forced to cancel the law against tax evasion, it could trigger "Possible surge of outflow of money in offshore". "This statement shake the very foundations of the UK," he said, adding: "This article 720 and 13, which basically reduces the ability of taxpayers to shelter their income and tax revenues with a simple way of obtaining them through offshore structures. In applying these provisions, "reopened the corporate structure" * (note: refers to the application of the doctrine of pierce the corporate veil) and offshore actual earnings are taxed in the UK. " "Those provisions – a key moment in UK law, aimed at combating tax evasion, and any changes can drastically affect the structure of the UK tax laws and how entrepreneurs would run their business and investment, "he suggested. "The Commission believes that discrimination exists to the extent that if individual to invest assets in companies in the UK (not EU companies), it will not pay taxes in the United Kingdom of Great Britain and the company will be taxed on profits. Concerns The Commission is that they regulate the transfer of assets to foreign companies only, but the rules go far beyond this, and regulate the transfer of assets to any foreign party. At present it is unclear to be whether taking any action against the Rules or in the aggregate only against the provisions on transfer of assets to non-resident in the UK but resident in the EU companies.
" "It is clear that we are entering a period of uncertainty. It is less clear how this period of uncertainty would be resolved – for example, should the UK government to respond to such difficulties by introducing such taxes for the existing UK companies? However, this method may charge the concerns of the Commission, may positively influence the key moments in UK tax policy. " "But one thing seems absolutely clear. The situation we know will change forever. All taxpayers must now decide how to adapt to change.
" Andrew Taylbi-Folkes, a partner in working with private clients of Ernst & Young, notes that these rules for years were very effective tool to prevent tax evasion by residents of Great Britain and the taxpayers who permanently reside in the country by placing their assets abroad. "However, – he said – if the UK will be forced to accept the changes recommended by the European Commission, the taxpayers of Great Britain and other countries will have more opportunities to use low-tax jurisdiction within the EU to reduce the tax burden. " Taylbi-Foulkes also noted that the rules impose some "significant challenges that will cause more problems." "The question arises of how this impact on foreign trusts? What happens if a company registered in the EU, which are owned by the British taxpayer, in turn, have subsidiaries outside the EU, which posted Investment? "- he said. "While the situation is not clarified, especially if the government will make further statements about the tax residency and permanent residents are unlikely to rich taxpayers would hurry reconsider the location of its assets ", – said Taylbi-Foulkes.