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Tax and the City briefing for February 2014

Helen Lethaby reviews recent developments affecting the City

High risk promoters and follower cases

HMRC is pretty unapologetic about loading the dice in its favour these days particularly when it comes to mass-marketed schemes. The majority of schemes under investigation involve the use of employment benefit trusts and offshore intermediaries to avoid payroll taxes and NIC sideways loss relief for partnership losses and SDLT. Yet the three new measures announced (along with draft FB 2014 legislation) on 24 January will have a much wider reach.

The proposals are (confusingly) spread across two documents: a consultation document entitled Tackling marketed tax avoidance; and a further document containing responses to the previous consultation Raising the stakes on tax avoidance.

HMRC has for some time been considering how best to...

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