ANTI AVOIDANCE

Tom McFarlane

Tom McFarlane (Alvarez and Marsal Taxand UK) presents an overview of Action 13.

Jason Collins

Jason Collins (Pinsent Masons) reports on the recommendations in relation to international dispute resolution.

Lori Hellkamp

Karl Kellar

Karl Kellar and Lori Hellkamp (Jones Day, Washington, USA) review the US response to the BEPS report.

Jim Harra

Jim Harra, HMRC's Business Tax Director General, explains HMRC's involvement and future activities on BEPS.

Peter Kiernan

Manraj Somal

Following HMRC’s recent consultation paper and proposed response document and draft legislation ahead of the Autumn Statement, Peter Kiernan and Manraj Somal (KPMG) answer questions on plans to make corporations criminally liable for tax evasion.

Jolyon Maugham

The decision in Lloyds Bank Leasing illustrates an inherent problem with TAARs which employ purpose-based tests to restrict the availability of tax expenditure reliefs: since the point of tax reliefs is to alter taxpayer behaviour, why then should taxpayers be denied relief for responding accordingly?

Philip Greenfield

Dr Richard Collier

Richard Collier and Philip Greenfield (PwC) review OECD's recommendations after publication this week of its final package of 13 reports constituting its base erosion and profit-shifting (BEPS) action plan.

The OECD has issued its final base erosion and profit-shifting (BEPS) recommendations to combat annual revenue losses estimated at US$100–240bn. The challenge now is to ensure measures are implemented consistently and coherently.

OECD recommendations hailed as ‘important milestone’, and the challenge now is to ensure measures are implemented consistently and coherently.

William Watson

William Watson (Slaughter and May) considers whether the forthcoming regime TAAR for loan relationships will be less problematic than what currently exists.

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