HMRC will be forced to defend itself in court against an allegation that it gave a ‘sweetheart tax deal’ to Goldman Sachs, The Guardian reported today.
HMRC requested comments by 11 May on a draft statutory instrument to amend regulations to allow investors in PAIFs to exchange their units in a dedicated PAIF feeder fund for units in the PAIF and vice versa, in specified circumstances, without incurring a capital gains tax charge.
A special low rate of UK corporation tax on finance profits from overseas financing within multinational groups will offer a ‘very significant’ benefit to groups setting up a structure that represents, according to a leading tax expert, ‘almost government-approved tax avoidance’.
The value of the retail prices index for March 2012 is 240.8 and RPI annual inflation stands at 3.6%.
Following FA 2010, exceptions to the deemed release rules are further restricted by Finance Bill 2012 with retrospective effect. David Southern analyses the background to and nature of these changes.
Mike Gibson examines the most significant developments in the Bill since publication of the draft provisions last year.
In this month's briefing, Helen Lethaby reviews recent developments including proposed changes to the rules on the deduction of income tax at source and the tax treatment of manufactured payments.
A union representing senior HMRC staff has questioned the government’s commitment to tackling ‘tax avoidance by big business and the wealthy’.
HMRC has published its guidance on the litigation and settlement strategy relaunched last July. The draft guidance was well received, HMRC said, with ‘very few comments on the actual material’.