EU Treaty tax planning for HNWIs

Jason Collins

How will HMRC react to the EC’s formal request that the UK amends anti-avoidance legislation?

On 6 December it was quietly announced in a Ministerial Statement released with the draft Finance Bill 2012 provisions that the UK is planning to change two key pieces of anti-avoidance legislation: the rules governing transfers of assets abroad (ITA 2007 ss 714 – 751) and the attribution of gains made by non-resident companies (TCGA 1992 s 13). Proposals will be published for consultation around the time of Budget 2012 with a view to enactment in Finance Bill 2013.

This was not an altogether surprising development. The European Commission announced in February 2011 that it had issued ‘reasoned opinions’ to the UK...

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How will HMRC react to the EC’s formal request that the UK amends anti-avoidance legislation?

This was not an altogether surprising development. The European Commission announced in February 2011 that it had issued ‘reasoned opinions’ to the UK...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes: