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ANTI AVOIDANCE


Card image Victoria Hine Leah Fisher Steven Porter
Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Paul Farey (AECOM) reviews the new rules and HMRC’s guidance.
A back to basics guide from Lexis®+ UK Tax.
The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).
Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.
HMRC are adopting a tougher stance with those who continue to deliberately mislead or refuse to cooperate, despite being in the COP 9/CDF process, writes Simon York CBE (Deloitte).
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
The Autumn Budget 2025 tightens anti-avoidance rules for share reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain what tax professionals need to be aware of.
Adam Craggs & Liam McKay (RPC) report a year marked by tighter procedural frameworks, clarifying case law and an intensified HMRC focus on both avoidance and criminal activity.
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