I’ve just read the draft legislation on this, available here. It’s good.
It covers obvious tricks e.g. disguised employments and loans. It also has a very targeted anti-avoidance provision. The definition of a bank works – as does that of an employee, I suspect.
But the real sting in the tail is that not only will banks be paying this additional tax – they also get no corporation tax relief on it – something I proposed on Monday. This does provide a real sting in the tail to this charge.
Good for Darling.