Question to the HM Treasury:

To ask Mr Chancellor of the Exchequer, how many BN66 status enquiries HM Revenue and Customs has made in (a) the UK, (b) Scotland, (c) England, (d) Wales and (e) Northern Ireland in each of the last five years for which figures are available.

UK residents are taxable on their worldwide income wherever it arises including situations where it arises by way of foreign partnerships. Budget Note 66 (BN66) did not change this position, but announced new legislation to put this position beyond doubt and to close down a wholly artificial tax avoidance scheme. This scheme involved foreign partnerships comprised of foreign trustees that sought to exploit a perceived loophole.

As section 58 of the Finance Act 2008, the legislation announced by BN66, retrospectively clarified existing legislation its introduction had no effect on any taxpayer’s tax position.

The information is not available to answer Question 225153. HMRC records are not collated so as to aggregate all enforcement actions taken in respect of all taxpayers.

The information is not available to answer Question 225154. HMRC systems do not separately identify cases with status issues from the generality of Section 58 cases.