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As public CbCR regimes expand, AI tools could be used to reveal patterns in global tax data, writes Will Morris (PwC).
The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
HMRC’s newly published materials raise important questions about how taxpayers are engaging with the UTT regime in practice, writes Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
The International Controlled Transaction Schedule is expected to be introduced in the UK in the foreseeable future. Andrew Stewart and Amy Clarke (BDO) explain how to prepare.
The tribunal decision in Currys on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
With joint and several tax liability being introduced for those contracting with umbrellas, David Harmer (Markel Tax) explains how to keep your clients protected.
CARF may be just the beginning of a new age of tax enforcement and scrutiny for the crypto industry, write Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
Fabian Barth (Alvarez & Marsal) examines the distinction between when an assessment is ‘made’ and ‘notified’.
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