HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)
The European Commission has published a letter sent to the Irish government which accuses it of having given illegal state aid to the US technology multinational Apple.
The government announced that the UK ‘is the first country in the world [out of 44 countries] to formally commit to implementing the new country by country reporting template’, which was unveiled as part of the OECD’s first seven recommendations on base erosion and profit shifting (BEPS), which t
Andrew Levene (BKL) sets out the tax issues on different options for structuring the purchase of freehold property
Exclusion of tax advantage on cross-border transactions
AIA and ‘qualifying persons’
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Jackie Wheaton (Moore Stephens) answers a query on a UK person investing in a US LLC that is tax transparent for US purposes
Capital allowance scheme failed
FID’s litigation: HMRC cannot rely on the standstill provisions