The Summer Budget announced several public consultations, including the use of deeds of variation (DOV) for tax purposes. Practitioners generally hoped that the intention to look at deeds of variation would be quietly dropped, assuming the March 2015 comments were purely to highlight a recent use of a DOV by the leader of the opposition.

HMRC has now announced a review to be closed on 7 October 2015, requesting evidence on the circumstances in which DOVs are used for tax purposes, the frequency with which they are used for tax purposes, comments on the way the current provisions are operating and to establish what changes, if any, should be made to the current tax rules.