ANTI AVOIDANCE

Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.

Tom Wilde

Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.

Nick Wright

Nick Wright (Jerroms Miller) examines when family investment companies deliver tax savings, weighing incorporation costs, profit extraction and inheritance tax benefits against the consequences of an eventual exit.

Gideon Sanitt

Victoria Braid

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

Helen Buchanan Gabrielle Van der Haegen Matthew Everett

Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.

Ross Birkbeck

With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).

Oliver Marre

Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.

Robert Langston

The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.

Helen Buchanan

Sarah Bond

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Craig Kirkham-Wilson

The APPG on responsible tax proposes criminally prosecuting tax advisers for avoidance planning. Craig Kirkham-Wilson (Simmons & Simmons) explains why the report is based on some misguided assumptions.

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