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James Bullock and Dennis Dixon McGrigors introduce this special issue on tax avoidance
There is perhaps an air of uncertainty in the world of tax avoidance. For years the rules of the game were as Peter Whiteman QC described things: 'a seesaw process between the well-advised taxpayer on the one side and the Revenue and Parliament on the other'.1 The cat-and-mouse game whereby devices are discovered by tax advisers and closed down by legislation has been a fixed part of the legal landscape. For a comparatively niche area of law tax avoidance has generated a large number of House of Lords cases.
Then HMRC changed the rules of the game. Instead of bringing in a general anti-avoidance provision HMRC has changed the economics of tax avoidance. The disclosure...

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