HMRC has amended, and the GAAR advisory panel has approved, the guidance on the general anti-abuse rule, with a new penalty regime proposed for cases caught by the rules. The Court of Appeal has held that a partnership acquiring, marketing and licensing film rights is not trading, so that leveraged tax relief is not available to the individual investors. BEPS papers are published on intellectual property regimes, the multilateral instrument, and country by country reporting. A surprise change to the capital allowance rules for sale and leasebacks where no capital expenditure is originally incurred.
