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ANTI AVOIDANCE


The European Parliament passed a non-binding resolution on 8 July calling for multinational corporations to adopt country by country reporting (which requires companies to report details of their financial performance, tax details, assets and employee numbers) in order to help fight tax evasion i

Liesl Fichardt and Robert Sharpe (Clifford Chance) review recent actions taken by tax authorities in WHT claims in relation to dividend arbitrage and similar arrangements.

Charles Yorke (Allen & Overy) reviews the Supreme Court’s decision in Anson v HMRC and its wider impact on entity classification.

Retrospective legislation was lawful 

Tori Magill (Pinsent Masons) considers whether recklessness in relation to an approved avoidance scheme can be deemed criminally culpable.
 
Will the Parent-Subsidiary Directive no longer be misused? Michael Anderson (Joseph Hage Aaronson) reviews the Parent-Subsidiary Directive’s new general anti-abuse rule and its impact on the UK.
 

Revenue & Customs Brief 9/2015 sets out HMRC’s position on the Littlewoods case.

The UN Conference on Trade and Development's World Investment Report 2015 argues that corporate tax anti-avoidance discussions should focus more on investment policy in developing countries and proposes a set of guidelines for coherent international tax and investment policies.

Expert insight on one of the most powerful weapons in HMRC's arsenal

Does the Supreme Court judgment in Pendragon represent a shift of emphasis? Can offshore schemes of the Newey-type scheme survive? Michael Conlon QC and Rebecca Murray (Temple Tax Chambers) examine the impact of recent case decisions on VAT planning arrangements.

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