Tax and the City briefing for January 2014

The Autumn Statement and FB 2014 contain few surprises, but there is the usual smattering of anti-avoidance provisions with immediate effect, including a measure aimed at preventing disguised distributions via total return swaps. Tax rules continue to evolve to cater for the post-financial crisis regulatory environment, with changes planned to deal with Solvency II and bank resolution scenarios. HMRC continues the fight against payroll tax avoidance, legislatively and through the courts. And, as the FTT decision in Versteegh shows, sometimes ‘killing the fly’ may be the only main purpose