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The Tower One St George Wharf Ltd v HMRC
SDLT anti-avoidance provisions trump connected companies market value rule exception
Planning for the substantial shareholding exemption following M Group Holdings
Robert Langston
The obvious conclusion from the Upper Tribunal decision is that every
standalone company should form a dormant subsidiary, writes Robert Langston
(Saffery Champness), but there are anti-avoidance rules to consider.
Back to basics: The GAAR
Sukhbir Binning
Ian Robotham
Unsure how the ‘double reasonableness’ test works? Sukhbir Binning and Ian Robotham (Pinsent Masons) provide a refresher guide to this ground-breaking legislation.
The new powers tackling promoters of avoidance schemes
Helen McGhee
Helen McGhee (Joseph Hage Aaronson) considers the new draft provisions
for inclusion in Finance Bill 2021 that strengthen three existing regimes.
Standards in tax: the influence of economics and politics on tax policy and tax professionals
Steve Edge
Steve Edge (Slaughter and May) discusses the competing objectives of
policymakers, advisers and taxpayers.
Private client review for June 2020
Sarah Albury
Andrew Goldstone
Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent tax developments affecting private clients.
DAC 6: six types of ambiguity
Elinor Boote
Dominic Lawrance
Dominic Lawrance and Elinor Boote (Charles Russell Speechlys) discuss the uncertainty of the reporting requirements and the potentially serious regulatory burdens for tax professionals dealing with international matters.
Private client review for April 2020
Moustapha Hammoud
Andrew Goldstone
Andrew Goldstone and Moustapha Hammoud (Mishcon de Reya) provide a
monthly update.
Self’s assessment: let’s clamp down on avoidance!
Heather Self
Heather Self (Blick Rothenberg) examines John McDonnell’s pledge to reduce avoidance.
Holistic construction
Angela Savin
Harry Smith
Two recent decisions have demonstrated conflicting approaches to the interpretation of multi-step transactions, write Angela Savin and Harry Smith (KPMG).
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Burlington: towards an international fiscal meaning of ‘main purpose’
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Is a loan earnings? Revisiting Rangers
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Katharine Wadia
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Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
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7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
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Re Waldorf Production UK plc
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Ask an expert: Dividend planning under the new close company reporting regime