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ANTI AVOIDANCE


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.

We are witnessing a government shakedown of the tax avoidance supply chain, write Richard Woolich and Geoffrey Tack (DLA Piper).
 
New rules will require large UK companies to publish their tax strategies. Researcher Maya Forstater reviews the 61 statements already published by FTSE 100 companies.
 
The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).
 
Sandy Bhogal (Mayer Brown) examines a recent tribunal case on whether certain insolvency procedures amount to a change of control for group relief purposes and looks at the potentially significant ramifications. 
 
BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.
 
Lynne Rowland (Kingston Smith) explains the proposed changes to DOTAS hallmarks for inheritance tax.
 
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