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
Mark Whitehouse, Tax Litigation, Reynolds Porter Chamberlain, discusses the proposals to extend the tax disclosure regime to NIC
In the second of two articles on simplifying treasury tax compliance, Roger Muray, tax partner, Ernst & Young LLP, outlines a second election designed to simplify tax compliance for hedging transactions
2006 saw significant activity but the key tax issues for UK plc remain unsolved. Joy Svasti-Salee, Head of International Tax, Grant Thornton UK LLP, considers what improvements are needed
In the second of two Back to Basic articles on private equity, Michael Bell and Vicki Carr, Tax Practice, Osborne Clarke, discuss the main tax issues for the private equity house and lenders
Gordon Keenay, Deputy Head of KPMG's Stamp Taxes Group, reviews this semi-mature tax against what we might have expected and asks where SDLT will go next