With recent events suggesting an increased interest from the EC in fiscal state aid, taxpayers would benefit from an early awareness of state aid risks, and advisers should also be careful to advise fully on these. Kelly Stricklin-Coutinho (Thirty Nine Essex Street) reports
Timothy Lyons QC (Thirty Nine Essex Street) looks at state aid and the European Commission’s investigations into Ireland’s tax ruling over Apple, and Luxembourg’s tax ruling over Fiat.
Toby Price and Martin Walker (Deloitte) consider the potential stamp tax traps arising on IPOs, including pre-IPO reorganisations and overallotment (or greenshoe) options, as well as offering practical solutions
The MOSS may not be so simple, but it is worth trying, writes Tarlochan Lall (Monckton Chambers)
Chris Lallemand (Smith & Williamson) discusses some contrasts between the UK implementing legislation for the UK/US IGA, equivalent US regulations and HMRC’s guidance
HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)
Taxpayers who wish to explore the possibility of resisting follower notices or accelerated payment notices received from HMRC should weigh up their options carefully. Patrick Cannon (15 Old Square) sets these out
The budget deficit should be falling fast as growth accelerates, but it is not – and government tax policy may be to blame, reports David Smith
Richard Collier and Philip Greenfield (PwC) examine the OECD’s first set of recommendations for tackling base erosion and profit shifting (BEPS) - finding few surprises, but no let up.
Darren Oswick (Simmons & Simmons) summarises the proposals in the relevant condocs and considers some of their ramifications