Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.
Oliver Marre (5 Stone Buildings) discusses the TOAA provisions in the light of the Fisher decision and asks: what should taxpayers do now to avoid penal income tax charges on offshore transfers?
In May, the EU General Court delivered two judgments on fiscal state aid. George Peretz QC (Monckton Chambers) explains why they still matter in the UK in light of the UK’s proposed state aid regime.
Rebecca Seeley Harris (RE Legal Consulting Ltd) explains the need for a comprehensive and constructive policy to protect both worker’s rights and revenues for the exchequer and the steps taken so far to regulate the industry.
A recent tribunal decision provides lessons on the settlement provisions, Ramsay and piercing the corporate veil, writes barrister Oliver Marre (5 Stone Buildings).
A recent tribunal decision on whether the taxpayer had an unallowable purpose is likely to be of wide application, as Heather Self (Blick Rothenberg) explains. But was it correctly decided?
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
