Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Anti avoidance
Home
Anti avoidance
ANTI-AVOIDANCE
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
The post-election (anti-avoidance) enforcement landscape
Ross Birkbeck
With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
Sehgal and the application of the remittance basis
Oliver Marre
Just as we contemplate the demise of the remittance basis, Oliver Marre
(5 Stone Buildings) examines the first Upper Tribunal decision on a key
provision on those rules.
Tax and the City review for April 2024
Mike Lane
Zoe Andrews
Recent decisions on intra-group VAT services, loan relationship debits and
distributions from non-UK resident company are examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Arguments before the Court of Appeal in BlackRock: is ‘just and reasonable’ a second bite of the cherry?
Neil Fletcher
Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
Tax and the Supreme Court in 2023
Constantine Christofi
The Supreme Court does strive to find a workable and straightforward interpretation of the law, writes Constantine Christofi (
EY).
Tax controversy in 2023: has inflation of taxing provisions been tamed?
Jason Collins
Ravikaran Ahlawat
Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
HMRC v Delinian Ltd (formerly Euromoney Institutional Investment plc)
Court of Appeal confirms share exchange anti-avoidance rule did not apply.
Go to page
of
7
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
Read all
Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
Read all
The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget