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Tax avoidance involving profit fragmentation

HMRC is inviting views on proposals to tackle avoidance schemes where profits of trades or professions are moved outside the UK tax charge.

Last fetched 03 May 2026 · gov.uk
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We are inviting views on proposals to tackle tax avoidance schemes designed to move UK profits outside the charge of UK tax, often using offshore trusts and companies.

The new legislation, which we intend to take effect in April 2019, would bring these profits within the UK tax charge and require notification of the arrangements to HMRC and earlier payment of tax.

We would welcome your comments on the proposals, to assist in the design of the legislation.

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Tax avoidance involving profit fragmentation · Order Paper · Order Paper