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TAX-AVOIDANCE


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 (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 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.
Jack Prytherch (Osborne Clarke) explains how the new scheme will apparently take inspiration from US and Canadian whistleblower models.
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
RBC reopens some old Ramsay uncertainties. Victoria Hine and Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Liquidation of parent company to preserve SDLT group relief did not have tax avoidance main purpose
Honest opinion defeats tax-scheme libel claim
Payments to employees under tax avoidance scheme were taxable earnings despite purported repayment obligation
TOAA applied on rent-free property settled in an offshore trust
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