HMRC seeks the upper hand over those who promote and participate in mass-marketed avoidance schemes, with more naming and shaming proposals and sanctions to force taxpayers to settle following HMRC wins. Dual contracts will no longer enable non-doms to claim the remittance basis for overseas employment income. New LLP proposals continue to be controversial, although they may be softened through guidance. Blackwell shows that the courts’ willingness to reach the ‘right’ answer may be a two-way street.
