The Government is right to avoid fettering the UK’s strong negotiating position following our notice under Article 50 being served by March 2017. There are many areas where some give and take might be appropriate to secure the best outcome for the UK. Tax, however, is not one of these areas and the Government needs to focus upon re-establishing the UK’s position as having the most attractive tax regime for both entrepreneurs and foreign direct investment. These focuses are complementary; there is no need to choose between entrepreneurs and foreign direct investment made by multinational companies as, generally, one is a customer and/or supplier for the other. The UK economy has interdependent business sectors and must ensure that it becomes even more globally competitive; merely ensuring that our tax rates and reliefs are the most competitive in Europe, frankly, lacks ambition. The formal negotiations leading up to Brexit will, of course, lead to both issues and opportunities. In my opinion, the latter are much more significant and nothing must be agreed that prevents us from seizing these opportunities after Brexit. As most tax advisers (generally being lawyers, accountants or both!) are pessimists by inclination, there is often a preference for accentuating the negative and finding a cloud around every silver lining. So far as the tax issues are concerned, it is important that HM Treasury (with the necessary input from HM Revenue & Customs) examine the changes which will occur when the European Union’s Parent-Subsidiary Company Directive no longer applies to the UK, after which it will need to fall back upon the provisions contained within the UK’s individual double tax treaties with each of the other EU member states. More often than not, changes to those treaties will not present any insurmountable hurdles but the speed of implementation of double tax treaties is often glacial. The risk is that, without such treaty changes, unnecessary taxes could arise upon UK subsidiaries and branches and it would be no comfort to UK business that the remaining members of the EU will be similarly, if not more, affected. Other areas where attention is needed include customs duties and Value Added Tax. The imposition of customs duties between the UK and the remaining EU27 would be costly for consumers, place a financial burden upon businesses and benefit no one. Hopefully businesses will be able to persuade their respective governments that this is the case and fight against damaging tariffs and other impediments to trade. Indeed, the UK government, post-Brexit, ought to look to repeal existing customs duties on trade with non-EU countries which are currently mandated by EU law (there are thousands of them) where, as is overwhelmingly the case, they are costly to either consumers or businesses. So far as VAT is concerned, there are good reasons why the UK should continue with this tax in, broadly, its present form, certainly until well after Brexit has occurred. The advantage of VAT over alternative purchase taxes is that, with some notable exceptions, it does not impose a sales tax upon goods and services which have already suffered sales taxation. There are, however, some exceptions to this approach for VAT. Firstly, the UK should, post-Brexit, substantially raise the threshold for compulsory registration for VAT to well above the existing threshold (of £83,000) prescribed by the EU. In my view, the compulsory registration limit should be increased to around £250,000 turnover per annum, thereby relieving most microbusinesses and many small businesses from compulsory registration for VAT and cutting their filing and other compliance costs. Doing so would, incidentally, have no noticeable downside impact upon the remaining EU27; in fact, they should do the same. Secondly, the UK may wish to flex the existing requirements to standard rate some consumer goods, for example in healthcare, where there has been a public demand to reduce the VAT currently applied. Thirdly, the EU VAT system, as enforced by the European Court of Justice, focuses upon a Continental European model for the delivery of financial services (including insurance) and favours the ‘in-house’ back-office business model as opposed to the outsourced approach adopted by many UK-based entities with the consequence being that they are unable to benefit fully from the VAT exemption for insurance etc. Rectifying this anomaly would be a sensible change post-Brexit and ought to result in reduced costs for UK consumers. In many ways, the opportunities following Brexit are much more interesting and are certainly likely to provoke even more debate. Examples, of which there are many, include: The removal of the European Court of Justice’s ability to overturn tax decisions in the UK tax courts. Hopefully, few will lament the removal of this unnecessary and often damaging supranational court from UK tax law. The removal of the EU’s gold-plating of the OECD’s/G20’s ‘Base Erosion, Profit Shifting’ (or ‘BEPS’) outcomes through its Anti-Tax Avoidance Directive (‘ATAD’). The UK has been one of the leading global proponents in the global BEPS project which seeks to prevent excessively aggressive tax abuse and avoidance by multinational companies; but there is no need for an additional set of complex rules leading to further compliance costs and adviser fees (although some lawyers and accountants might, understandably, disagree!) The scope to liberalise and democratise the tax reliefs for enterprise investment schemes (‘EISs’) and seed enterprise investment schemes (‘SEISs’) which, as HM Treasury ministers often say, are currently constrained by the complex rules in the EU to prevent what is, bizarrely, perceived to represent prohibited ‘state aid’ for these entrepreneurial companies. So far as future changes to EIS and SEIS are concerned, the UK government should look to other global jurisdictions beyond Europe and enact the best rules in other successful, entrepreneurial economies such as the United States to facilitate securing equity capital by start-up and scale-up businesses to accelerate their growth. In conclusion, as for other matters within the Brexit negotiations, the UK government should listen to businesses of all sizes and across all sectors and, of course, also to individual taxpayers before determining its strategy for the taxation aspects of the negotiations leading to our exit from the EU following the favourable outcome of the EU referendum. Most importantly, it should maintain its flexibility in these negotiations so that it can focus upon addressing the principal tax issues which would otherwise arise whilst preserving its freedom for future bold tax reforms and, hopefully, significant tax simplification for both businesses and individuals.