HMRC has restricted the availability of the Liechtenstein disclosure facility (LDF). The restrictions are subject to three key exclusions; these are not as clear cut as one might think, writes Simon Airey, head of tax investigations, DLA Piper
HMRC is not having a good run on cases concerning VAT cost recovery, writes Graham Elliott, consultant at Withers
Recent changes to the SDRT regime go against the drive to make UK asset management industry more competitive, writes Suzi Edwards, senior manager at PwC
Can the trend for tax inversions survive an assault from the US Treasury department? Adam H Rosenzweig, professor of law at Washington University School of Law, assesses the situation.
Who is saying what
Stefano Mariani summarises ‘a cautionary tale of wide judicial latitude in statutory construction’ in Wintershall
Jonathan Cooklin (partner) and Dominic Foulkes (associate) of law firm Davis Polk comment on the current trend of US corporate inversions.
Peter Vaines asks if ATED is tax deductible
Heather Self considers the changes made to the Model Tax Convention (MTC) and what these updates mean in practice.
James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.