ANTI AVOIDANCE

David Pett

All but one of the loan charge review’s ‘hard’ recommendations have been accepted. David Pett (Temple Tax Chambers) assesses both the review and the Government’s response – and considers the implications for affected taxpayers and the new settlement opportunity.

Ross McGregor

Hannah Manning

There is a myriad of anti-avoidance legislation which must be carefully considered throughout the lifecycle of a close company. Hannah Manning and Ross McGregor (Travers Smith) explain how to avoid some of the common pitfalls.

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.

Sinisa Butina

Angela Savin

Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper Tribunal’s reasoning in Scatola and the broader ramifications for taxpayers seeking certainty and finality to their SDLT affairs.

Ritchie Tout

The recent changes to the Employee Ownership Trust rules bring the regime back to its intended purpose – and may impact many valuations, writes Ritchie Tout (Azets).

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.

Tom Wilde

Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.

Gideon Sanitt

Victoria Braid

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

Helen Buchanan Gabrielle Van der Haegen Matthew Everett

Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.