Issue 1203

Analysis

• The OECD’s discussion draft on transfer pricing documentation and country by country reporting
• Donovan, dividend waivers and settlements
• VAT focus: TOGCs and VAT groups
• LMA facility agreements – negotiating the norms
• Economics focus: The 50% top rate makes a comeback
• Briefing on the House of Lords Economic Affairs Finance Bill Sub-Committee
• Adviser Q&A: HMRC’s two recent consultations on tackling avoidance

In brief

• 31% increase in judicial review applications against HMRC
• New rules for dual contracts: ‘puzzling on a number of levels’

News

• Big business paying more NIC than corporation tax
• Online submissions reach record level
• Deadline extended for filing returns
• New measures target promoters of avoidance schemes
• TAAR on capital losses set for revision
• UK TOMS rules will not change following Spain ruling
• Services received by pension fund can be general costs
• In brief: BEPS; FATCA; film relief; CITB; Notice 702; biofuel; DOTAS; ESCs
• Partnership rules will harm genuine LLPs, peers told
• Press watch: CBI calls for tax breaks on private equity

Cases

• Litman & Newall v HMRC
• Southern Cross Employment Agency Ltd v HMRC
• Associated Newspapers v HMRC
• Secrets v HMRC
• Blackwell v HMRC
• Nicholas Barnes v HMRC
• Ghelanis Superstore v HMRC

One minute with

• One minute with... Susan Ball

Ask an expert

• Ask an expert: Is money received from scrap metal part of a UK property business?

Practice guides

• LMA facility agreements – negotiating the norms