The Tax Journal brings you extracts from Ernst & Young's 2007 Budget Alert. Ernst & Young's comments are in italics
Ian Latter, Partner, and Neil O'Brien, Director, KPMG's UK M&A Tax team, explain the potential benefits of the increasingly popular 'Opco/Propco' structure in the context of M&A and discuss the related tax hazards
David Pett, Tax Partner at Pinsent Masons, writes about a new form of employee share incentive scheme arrangement, the executive shared ownership plan (ExSOP)
Pete Miller, Tax Director, Ernst & Young LLP, looks at the development of the Disclosure of Tax Avoidance Scheme (DoTAS) regulations
James Bullock and Dennis Dixon, McGrigors, introduce this special issue on tax avoidance
Rupert Shiers of McGrigors LLP and Pete Miller of Ernst & Young LLP review the history and interpretation of 'whole or main' purpose test
Rachel Morrison, Director of Group Taxation & Accounting at Alliance & Leicester plc, presents an industry perspective of tax avoidance
James Dixon1 highlights the extraordinary breadth of situations considered by the Tribunals in their lifetime so far
In the second of two articles, Richard Fletcher and Geoffrey Kay, Baker & McKenzie LLP, consider the OECD Report on the Attribution of Profits to Permanent Establishments
Following the recent articles on private equity, Anton Hume & Nick Drizen explore in more detail the new 'acting together' transfer pricing provisions and how to maximise planning opportunities within the new regime