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COMPLIANCE


HMRC has confirmed it is offering an extended self-assessment filing deadline for severe weather.

Finance (No.2) Act 2015 introduced a surcharge of 8% on the taxable profits of banking companies arising on or after 1 January 2016.

HMRC has revised its interpretation of the residence articles in 16 double taxation agreements, taking the view that a tie-breaker clause should be used to decide a company’s residence. Previously, HMRC regarded dual-resident companies as outside the scope of the treaties.

Unsuccessful loan relationship avoidance scheme

Following HMRC’s recent consultation paper and proposed response document and draft legislation ahead of the Autumn Statement, Peter Kiernan and Manraj Somal (KPMG) answer questions on plans to make corporations criminally liable for tax evasion.
 

TAXE Committee gives multinationals ‘one more chance’ to turn up, reports Tim Law (Engaged Consulting)

Peter Jackson (Taylor Wessing) examines the tax issues surrounding a UK REIT group which wishes to purchase shares in a UK resident and a non-UK resident SPV.

Tim Law (Engaged Consulting) takes a look at the consultation document on improving large business tax compliance, and the three proposed measures contained therein. 
 
The war on non-compliance continues apace, writes James Bullock (Pinsent Masons).
 

When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.

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