UK businesses should only engage in “reasonable tax planning that is aligned with commercial and economic activity and does not lead to an abusive result”, the CBI said yesterday in a statement of tax principles designed to “advance the debate on responsible managem
HMRC published draft regulations last week to provide a further exception to the income distribution requirement for investment trust companies at regulations 19 and 21 of the Investment Trust (Approved Company) (Tax) Regulations (SI 2011/2999).
HMRC has published draft regulations to address technical issues in the operation of The Offshore Funds (Tax) Regulations 2009. “As industry is keen to have the proposed changes introduced as soon as possible, this consultation is for four weeks,” HMRC said.
The ability of multinational groups to exploit differences between national tax systems to reduce their tax bills without breaching transfer pricing rules is explained in a new HMRC briefing.
No country has the enforcement resources required to perform a thorough audit of every possible transfer pricing issue, the OECD has noted in the introduction to a draft Handbook on Transfer Pricing Risk Assessment, published on 30 April.
HMRC’s former head of tax advised colleagues against revisiting a settlement with Goldman Sachs partly because of concern that the company’s reaction might cause “major embarrassment” to the chancellor and HMRC, the High Court heard yesterday.
David Barton sets out the key issues for advisers to consider this month.
Are the rules on the taxation of perpetual debt in perpetual motion? William Watson reviews the state of play.
The rules have tightened with effect from 20 March. Paula Tallon and Paul Howard explain why the new provisions may force companies to consider the true nature of transactions with their shareholders.