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VICIOUS tax planning

May 3, 2013

For years, I have clipped out cuttings from newspapers, scanned articles, saved snippets. Sometimes I send the clippings to clients or friends; often I keep them for myself, quite often I put them somewhere safe, forget where they are, and then one day happenchance upon them.

There is one article which I didn't keep, but wish I had. An article from Taxation magazine, if I recall, or maybe (and I think this might be the case) from its sister magazine, Tolley's Practical Tax, which I used to get twenty years ago.

It is an article which has been a foundation stone of my career. It taught me to also do VICIOUS tax planning, and for years I have told colleagues about it.

In writing about it, I don't need to fear Margaret Hodge. VICIOUS isn't aggressive, abusive or malevolent. It is an mnemonic, a tool to remind professionals to address problems from more angles than the specific one in the client's mind, or the specific one in your mind.

VICIOUS stands for:


Income Tax

Corporation Tax

Inheritance Tax

Other Taxes

Uniform Business Rates

Stamp Duty

UBR was a 'tax' which, when the article was written- I think in the 1980s, had to be born in mind. I vaguely recall that, for instance, intra-group transfers of trade, which might otherwise be the right thing to do, sometimes caused penal hikes in UBR-because of loss of reductions or reliefs. But the specific meanings of U, O, and others, is unimportant: VICIOUS is merely a tool to say 'don't just think of [say] corporation tax: given some thought to [say] VAT, stamp taxes…, look at matters in the round.

Time and time again, for more than two decades, VICIOUS has been useful to me. It is relevant to my work on a daily basis. Thank you, to the author, whoever you were.



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