TAX-AVOIDANCE

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

David Pett

All but one of the loan charge review’s ‘hard’ recommendations have been accepted. David Pett (Temple Tax Chambers) assesses both the review and the Government’s response – and considers the implications for affected taxpayers and the new settlement opportunity.

Claire Miles

QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...

Ross McGregor

Hannah Manning

There is a myriad of anti-avoidance legislation which must be carefully considered throughout the lifecycle of a close company. Hannah Manning and Ross McGregor (Travers Smith) explain how to avoid some of the common pitfalls.

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.

Zoe Andrews

Mike Lane

Osmond, Eastern Power Networks and HMRC’s guidance on their new unilateral APA process are among the developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Zoe Andrews

Mike Lane

The application of Ramsay in a recent case and HMRC’s revised guidance on salaried members are among the topics covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.

Katie Oliver

Gary Barnett

Katie Oliver and Gary Barnett (Simmons & Simmons) review the latest decisions on VAT recovery and an AG opinion on the application of market value provisions in the VAT Directive.