The courts have recently shown the extent of their appetite for purposive construction in tax avoidance cases. HMRC published a list of disclosure numbers that may be targeted for accelerated payment notices. There is yet another consultation on DOTAS. Changes to loan relationships and derivative contracts regulations are announced to help ease the transition to new UK GAAP. The Court of Appeal considers the effect of a notice clause in a tax indemnity on liability to pay. After a 13 year wait, we have a new Stamp Taxes on Shares Manual.
