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Impact of UK Retrospective Tax Legislation

Jon Molyneux made this Official Information request to Inland Revenue Department

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From: Jon Molyneux

Dear Inland Revenue Department,

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 260+ New Zealand residents who worked as contractors in the UK between 1999-2019?

• Any indication from HMRC how many New Zealand residents will be impacted by this over and above the 260 letters they have already sent to New Zealanders?

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

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

• Any justifications for taxing New Zealand 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 Inland Revenue department stands on enforcing retroactive, or effectively retrospective, tax legislation under MARD agreement?

Yours faithfully,

Jon Molyneux

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From: oia
Inland Revenue Department

[IN CONFIDENCE RELEASE EXTERNAL]

Good morning,

Thank you for your request made under the Official Information Act 1982. We will respond to your request within 20 working days from the date of receipt.

Kind regards,

Government & Executive Services

-----Original Message-----
From: Jon Molyneux <[FOI #9655 email]>
Sent: Sunday, 24 February 2019 4:17 PM
To: oia <[IRD request email]>
Subject: Official Information request - Impact of UK Retrospective TaxLegislation

Dear Inland Revenue Department,

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 260+ New Zealand residents who worked as contractors in the UK between 1999-2019?

•Any indication from HMRC how many New Zealand residents will be impacted by this over and above the 260 letters they have already sent to New Zealanders?

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

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

•Any justifications for taxing New Zealand 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 Inland Revenue department stands on enforcing retroactive, or effectively retrospective, tax legislation under MARD agreement?

Yours faithfully,

Jon Molyneux

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From: oia
Inland Revenue Department


Attachment Jon Molyneux OIA response.pdf
772K Download View as HTML


[IN CONFIDENCE RELEASE EXTERNAL]

Dear Mr Molyneux

Please find attached a response to your Official Information Act request
of 24 February 2019.

 

Kind regards

Government and Executive Services

 

 

This email and any attachment may contain confidential information. If you
have received this email or any attachment in error, please delete the
email / attachment, and notify the sender. Please do not copy, disclose or
use the email, any attachment, or any information contained in them.
Consider the environment before deciding to print: avoid printing if you
can, or consider printing double-sided. Visit us online at ird.govt.nz

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