Tax lawyers have welcomed government concessions that should lessen the impact on law firms of plans to make the promoters of tax avoidance schemes disclose them to the Inland Revenue.

Lobbying over clauses 290 to 302 of the Finance Bill led to changes last week to the draft regulations, explanatory notes and initial guidance underpinning the plans.


As a result, only those at the heart of a scheme or arrangement will be treated as promoters. The revised regulations exclude anyone who is not involved in those parts of the scheme that give rise to a tax advantage, such as someone dealing only with the company law aspects, and most people responsible for the organisation or management of the scheme.


The Law Society's tax law committee has lobbied heavily over the provisions, and its chairman, Linklaters partner Michael Hardwick, said the changes will 'make it much easier for [law] firms to comply with the rules'.


He added that 'it does look like it will limit the impact on firms', especially those that just document tax-avoidance schemes. Solicitors who provide tax advice on schemes will be caught, he said.


The Society has also welcomed a later commencement date for the provisions - schemes promoted on or after 22 June will have to be disclosed, rather than from 18 March.


Mr Hardwick said discussions will continue over which schemes will be caught - the committee is concerned that routine tax planning may be affected - and also what should be covered by legal professional privilege and so need not be disclosed.