Andrew Roycroft (Norton Rose Fulbright) considers the Upper Tribunal decision in Trigg and the interesting comments on the application of the Ramsay principle, particularly its application to closely articulated or prescriptive legislation.
Your monthly round-up of tax issues affecting the City, by Mark Middleditch (Allen & Overy).
Peter Mason (Rosetta Tax), David Jordorson (Association of British Insurers) and Hamish Garnett (MetLife) review the recent Aspiro decision and assess its impact on UK insurance supply chains and insurance intermediary services generally.
The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
Given the potential tax savings and its potentially wide application, tax advisers will need to understand and advise on the new investors’ relief for investments in trading companies or trading groups, write Dipan Shah and Nick Baker (PwC).
Helen Buchanan (Freshfields Bruckhaus Deringer) examines the revised draft legislation and new draft guidance on the proposed corporate offence of failing to prevent facilitation of tax evasion.
The Finance Bill hybrid mismatch legislation significantly expands the scope of the December draft legislation. James Ross (McDermott Will & Emery) reviews the changes.