Tax Collection and Management (Wales) Act 2016 section 81E

Adjustments to counteract tax advantages

Section 81E gives the Welsh Revenue Authority (WRA) the power to make adjustments to counteract tax advantages arising from artificial tax avoidance arrangements.

• WRA may make adjustments it considers just and reasonable to counteract a tax advantage that would arise from an artificial tax avoidance arrangement.
• Adjustments can be made not only to the devolved tax directly involved, but also to any other devolved tax.
• Adjustments must be made either by amending a tax return through a closure notice (where an enquiry is in progress) or by means of a WRA assessment in all other cases.
• WRA cannot make any adjustment unless it has first complied with the required procedural steps set out in sections 81F and 81G, which involve issuing notices to the taxpayer.