ANTI AVOIDANCE

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

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Simon York CBE

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

Cristy Ajediti

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.

Peter Morley

Jamie Robson

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

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.

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.

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