Barclays insisted that its tax arrangements were within ‘the letter and spirit’ of HMRC’s Code of Practice on Taxation for Banks after the government announced retrospective legislation to close two ‘highly abusive’ tax avoidance schemes.
An updated ‘Gateway’ features in HM Treasury’s latest update on CFC reform, published yesterday.
James Wilson sets out a risk-based approach to the rules.
Mike Lane explains why the regime may be susceptible to challenge under EU law.
Aurell Taussig provides a flowchart on the new regime.
Martin Lambert and Zoe Wyatt provide a practical guide.
Michael Bird and Jonathan Bridges examine IP issues.
From Kevin Ashman, Tony Beare, Andrew Boucher, David Clissitt, Elizabeth Conway, Jonathan Cooklin, David Harkness, Robert Edwards, Aurell Taussig, Duncan Whitecross, James Wilson, Mark Edwards, Paul Morton and David Smith.
Chris Morgan provides this month’s briefing on international matters, including the latest on FATCA developments.