The five key 2010 issues for in-house tax teams are: the change in the corporate tax environment under the new government – ‘Britain open for business’; the new approach of HMRC in classifying companies as ‘low risk’ corporate; alternative dispute resolution; emerging from the economic downturn; and the reporting of uncertain tax positions. 2011 is likely to see a major focus on IP, onshore in terms of encouragement of innovative activity and offshore in terms of the treatment of CFCs and perhaps an increasing public scrutiny of the tax position of the largest companies which will provide food for thought for in-house tax teams as well as boards.