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IN BRIEF

Views on recent developments in tax.

Tottenham Hotspur and termination arrangements.
 

A non-confidential version of the Commission’s ‘McDonald’s’ decision has been published, reports Pierre-Régis Dukmedjian & Alejandro Dominguez (Simmons & Simmons Luxembourg LLP).

Ian Young responds to points raised by Andrew Hubbard about the new 2016 charter arrangements. The Charter Committee is now at the heart of the HMRC organisation. Ian Young explains how we got to the present position, right back to the first charter in 1986, and what HMRC will need to do to make Your Charter a positive feature of the UK tax system in the future. 

‘Condition C’ has proved to be a successful ground of challenge for taxpayers contesting the validity of APNs in judicial review proceedings.
 

An odd thing happened the other week, writes Tax Information and Impact Note (TIIN) specialist Wendy Bradley.

It is not in the public interest to tax the same profits twice.
 

The EC’s Anti-Tax Avoidance Directive (ATAD) is likely to be implemented, in some form, within the next few months.

Chris Davidson (KPMG) believes that HMRC has misinterpreted the 2004 DOTAS rules by issuing APNs on the basis that they are substantially the same as a previous transaction that was notifiable under DOTAS. 
 
Claims that leaving the EU would free up public money for other priorities have been disproved by experts, who say that Brexit would harm, not help, the public finances, as David Smith reports.
 
John Whiting (Office of Tax Simplification) outlines the OTS’s new project on reviewing the corporation tax computation.
 
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