ANTI AVOIDANCE

Giorgia Maffini (PwC) considers whether OECD transfer pricing reforms will deliver simplification or greater scrutiny, focusing on intra-group services, Amount B and growing differences between jurisdictions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

A report by Lexis®+UK Tax

Paul Townson

Chris Holmes

Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

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).

Ros Martin

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

Paul Farey (AECOM) reviews the new rules and HMRC’s guidance.

A back to basics guide from Lexis®+ UK Tax.

Aparna Nathan

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).

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