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
James Bullock and Jason Collins, McGrigors LLP, review the tactics and procedures involved in HMRC enquiries in avoidance cases
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
Michael Conlon QC of Pump Court Tax Chambers considers the latest wisdom on single supply
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
Chris Morgan, Head, and Jonathan Bridges, Senior Manager, KPMG's International Corporate Tax Group, comment on the Court of Appeal's decision in the long-running M&S EU group relief case
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