Mark Middleditch (Allen & Overy) examines the themes that have dominated 2016 for the City, including the anti-hybrid rules brought on by the UK’s enthusiasm for BEPS, and looks at 2016’s case law, which shows that HMRC continues its run of success in defeating tax avoidance schemes.
Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.
The proposed corporate offence for failing to prevent tax evasion is now set out in the Criminal Finance Bill, and HMRC has issued revised draft guidance. Jason Collins and Tori Magill (Pinsent Masons) outline the ways a relevant body can manage their exposure to risk.
Mark Middleditch (Allen & Overy) provides this month’s review of tax developments affecting the City.
Tim Law (Engaged Consulting) examines the first step of the European Commission’s second attempt at compiling a list of ‘non-cooperative’ jurisdictions.
The worldwide disclosure facility is now open and higher penalties and sanctions will apply from 30 September 2018 for non-compliance. Helen Adams and James Kennedy (BDO) examine its terms.