As stated in our response to HMRC’s earlier GAAR consultation (September 2012), the ACT is supportive of the principle of reducing abusive tax schemes, and recognises that the proposals issued in December 2012 provide more certainty than the previous proposals.
However uncertainty of scope still remains and this together with the inability to clarify any ambiguity through a pre-clearance process does not make the UK an attractive location for both indigenous and foreign businesses to invest in.