“The Exchequer Secretary has claimed that these measures are not retrospective. However, this statement is false.
“The changes will apply to any legitimate and registered tax planning arrangement entered into as far back as 2004, and retrospectively change the way that tax disputes are dealt with. There is the real danger that if the Exchequer Secretary is allowed to defend this legislation by saying that the changes are not retrospective, MPs may be misled into passing an extremely draconian and unjust retrospective change to the law which will have serious financial repercussions for tens of thousands of businesses and individuals. Indeed, you will be aware that the Treasury Select Committee has strongly criticised this aspect of the legislation and said that the Government has not made a case as to why these measures should apply retrospectively.
It is surely perfectly reasonable that any new tax legislation should only apply going forward, and should not be applied retrospectively to those cases which are already in the system.”