Christina HJI Panayi (Queen Mary University of London) identifies the main EU tax developments in 2016, including the anti-tax avoidance package, decisions in state aid cases, the reform of corporate tax and the relaunch of the common consolidated corporate tax base.
Mark Middleditch (Allen & Overy) examines the themes that have dominated 2016 for the City, including the anti-hybrid rules brought on by the UK’s enthusiasm for BEPS, and looks at 2016’s case law, which shows that HMRC continues its run of success in defeating tax avoidance schemes.
Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.
Michael Collins (Temple Tax Chambers) looks at the unfortunate consequences of new FA 1986 s 77A for share-for-share exchanges in advance of company reorganisations.
Simon Whitehead and Joseph Irwin (Joseph Hage Aaronson) review the Court of Appeal’s recent judgment in the franked investment income group litigation.
Vinny McCullagh (Grant Thornton) reviews Heating Plumbing Supplies Ltd where the court decided that a VAT group’s activities must be taken as a whole.
Peter Dylewski and Philippe Gamito (KPMG) considers the implications of the AG ruling in Commission v Luxembourg and the future availability of the cost sharing group exemption in the UK and other member states.
This tracker provides an A to Z guide to the tax consultations which are currently open for comment and those consultations which have recently closed where an outcome has been announced.
Matthew Hodkin (Norton Rose Fulbright) considers some enlightening detail on a new proposal to introduce a wider exemption than first contemplated by the consultation process.
Patrick Ford (Squire Patton Boggs) reports on the termination payments and salary sacrifice arrangements provisions.