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ANTI AVOIDANCE


Mark Middleditch (Allen & Overy) provides this month’s review of tax developments affecting the City.

Gideon Sanitt (Macfarlanes) reviews the decision in Ingenious Media and to what extent HMRC will be held to its duty of confidentiality.
 
Eloise Walker (Pinsent Masons) considers the latest OECD proposals for banks under the BEPS Action 4 interest restrictions, and what they might mean for the UK banking sector.
 
Graham Aaronson QC (Joseph Hage Aaronson) presents a personal view of tax avoidance in the UK over the past 100 years, looking at the case law and legislation which developed in the first half century, and the social and economic context in which they evolved.
 

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.

Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.
 

The express aim of the proposed changes is to simplify the current position. However, the draft legislation suggests that the opposite might well be the result. Alasdair Friend (Baker & McKenzie) reviews the consultation document.

HMRC’s new consultation highlights a number of administrative changes which could make life easier for HMRC and taxpayers. However, a couple of the proposals to change substantive tax charges may have unwanted side effects, writes James McCredie (Macfarlanes).
 

Andrew Scott (Pinsent Masons) considers the various linguistic concepts in determining taxpayer conduct towards paying tax.

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