ANTI AVOIDANCE

The monthly review of tax issues affecting the City, by Mark Middleditch (Allen & Overy).

Pete Miller

Pete Miller (The Miller Partnership) examines HMRC’s win in Hancock, where the Upper Tribunal decided that a redemption of loan notes had triggered a charge to CGT.

Andrew Hubbard

Tax advisers are going to be required by law to inform their clients about the dangers of not declaring offshore income using wording specified by HMRC. No harm in that, you might think, but where does it end?

Peter Vaines

Peter Vaines (Field Court Tax Chambers) suggests it is time for Parliament to step in to counter unintended consequences of APNs.

Jonathan Hare Stephen Morse Peter Halford

Jonathan Hare, Stephen Morse (PwC) and Peter Halford (PwC Legal) answer the key questions on the European Commission’s investigations into alleged illegal state aid as a way of tacking perceived corporate tax avoidance.

Chris Morgan

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including the EC’s anti-avoidance package; challenges to the UK’s 45% tax rate on restitutional interest; and key tax developments from around the world.

Heather Corben

The European Commission has published its ambitious anti-tax avoidance package. Heather Corben (King & Wood Mallesons) reviews the proposals.

James R Modrall

Following the European Commission’s announcement that the Belgian excess profit tax scheme is not compatible with state aid rules, James R Modrall (Norton Rose Fulbright) considers the practical implications of the decision.

Jason Collins

Jason Collins (Pinsent Masons) warns that businesses which fail to make adequate disclosures on tax issues might find themselves within HMRC’s sights – and potentially subject to a criminal investigation.

Tax advisers have welcomed the government’s decision to restrict the use of a new ‘strict liability’ offshore tax evasion criminal offence to situations where the amount of tax underpaid is £25,000 or more.

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