TAX-AVOIDANCE

Louis Triggs

Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.

Rob Sharpe

Richard Sultman

Key points to note.

A practical guide by Lexis®+ UK Tax examining when a non-statutory clearance is the right route, how to frame the application and how far HMRC’s response can be relied upon.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

Aparna Nathan

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...

Hannah Manning

Ross McGregor

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.

Mike Lane

Zoe Andrews

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).

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