Martin Zetter considers alternatives to the arm’s length principle in light of the OECD’s work on base erosion and profit shifting.
Jonathan Levy considers recent criticisms of HMRC by the PAC, and believes that the time has come for more prosecutions, particularly for complex tax frauds
Reader feedback from Nicholas Jordan and David Harkness on the problems of trying to apply GLO procedures to the tribunal lead case rule.
Philip Fisher considers the impact of the FTT decision in Martin concerning tax relief for negative earnings.
Peter Vaines believes that HMRC is wrong to now treat specialty debts as situated where the debtor resides, rather than where the relevant document is found.
Ray McCann suggests that HMRC's attempt in Charlton to use TMA 1970 s 29 to correct its own error is in breach of its litigation strategy and is contrary to assurances given when the DOTAS regime was introduced.
Paul Aplin reflects on a recent parliamentary debate on HMRC, and is pleased to hear MPs acknowledging the link between resource and service delivery.
Chris Sanger reflects on the future for corporation tax.
Eloise Walker explains why there is much to cheer in the draft Finance Bill provisions concerning the climate change levy.
David Harris believes that the forthcoming GAAR should be counterbalanced by a ‘GRACE’