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ANTI AVOIDANCE


Glencore: MAPping unchartered territory premium
Card image Emily Szasz
Card image Charlotte Anderson
Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.
13 September 2019
Contentious tax: quarterly review premium
Card image Adam Craggs
Card image Michelle Sloane

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC. 

4 September 2019
Comment: In defence of the ‘outstanding loan’ charge premium
Card image David Pett
David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
3 September 2019
UK implementation of DAC 6
Card image Zoe Andrews
Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.
23 July 2019
Comment: A concerning erosion of rights to appeal
Card image Michael Thomas KC
Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.
9 July 2019
Facilitation of tax evasion: the reality of prevention procedures premium
Card image Matthew Norris
It is now 18 months since the entry into force of the UKs corporate criminal offences of failing to prevent the facilitation of tax evasion. This milestone coincides with the publication of Ipsos Moris research report, as part of the...
18 April 2019
Developments in HMRC’s extra-territorial powers premium
Card image Matthew Fleming
Card image Chris Leigh
Matthew Fleming and Chris Leigh (KPMG) examine the legal developments that strengthen HMRC’s ability to tackle cross-border non-compliance. 
28 March 2019
Atherton: challenging a discovery assessment premium
Card image Helen Adams
Helen Adams (BDO) considers the extent of HMRC's powers on discovery in the light of recent case law.
13 March 2019
OECD’s consultation on the tax challenges of digitalisation premium
Card image Jeremy Webster
Jeremy Webster (Pinsent Masons) considers the OECD’s public consultation document aimed at providing a consensus-based long-term solution.
 
21 February 2019
The profit diversion compliance facility: a welcome opportunity or a trap to be avoided? star
Card image Mike Lane
Card image Steve Edge
Steve Edge and Mike Lane (Slaughter and May) examine the new TP/DPT disclosure facility that was announced by HMRC last week.
 
17 January 2019
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