Tax and the City briefing for July

HMRC publishes a draft GAAR for consultation; whilst largely based on Aaronson’s GAAR, it raises further concerns about impartiality. In Greene King, judges put their accounting hats on and do not shy away from a punitive double taxation result in a tax avoidance case. HMRC publishes its views on perpetual debt and the implications of statutory bail-ins. Further guidance on the Banking Code of Practice focuses on promotion and facilitation aspects.