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ANTI AVOIDANCE


The substantial shareholdings exemption is in danger of being misunderstood, warns Heather Self (Pinsent Masons)

Andrew Goldstone and Charlie Sosna (Mishcon de Reya) round up the latest private client news, including: the remittance basis charge consultation; a report on tax incentives for art; Hutchings; and BiGDUG Limited Remuneration Trust (from Guernsey)

HMRC has announced that the Court of Appeal has ruled in its favour against Eclipse Film Partners (No 35) LLP, which it said ‘protected an estimated £635m in tax’.

Following the censure HMRC received over the HSBC ‘Swiss leaks’ before the Public Accounts Committee on 11 February, as well as further press criticism, HMRC issued a statement on when and how it came by the leaked HSBC Suis

Tori Magill (Pinsent Masons) answers a query on a client who participated in a marketed avoidance scheme and has received a COP9 notice

In this month’s briefing, Mark Middleditch (Allen & Overy) provides a round-up of recent tax developments affecting the City, including: the decisions in Sir Fraser Morrison (contingent CGT liability for shareholder-director) and Project Blue (SDLT anti-avoidance); new tax relief for corporate rescues; and the Office of Tax Simplification’s report on partnership taxation.

Dawn Register and Helen Adams (BDO) take a look at the consultation proposals to strengthen sanctions for tax avoidance

Following the conclusion of its inquiry into PwC and Shire Pharmaceuticals following the ‘LuxLeaks’ furore, the Public Accounts Committee (PAC) has released its report on tax avoidance and the role of large accountancy firms

HMRC has defended its record in recovering tax on undeclared Swiss bank accounts through the tax agreement with Switzerland, which came into force in January 2013. The agreement was signed in 2011, following information leaked by a Swiss bank employee on hidden accounts (the ‘Lagarde list’).

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