Taxpayers who wish to explore the possibility of resisting follower notices or accelerated payment notices received from HMRC should weigh up their options carefully. Patrick Cannon (15 Old Square) sets these out
Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent updates in the private client arena, including: the proposed new strict liability criminal offence; changes to the LDF; the common reporting standard in the UK; strengthening DOTAS and the VADR; and the Presumption of Death Act.
Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
Andrew Roycroft (Norton Rose Fulbright) reviews the decision in the case of Bupa Insurance, which serves as a reminder that a tax avoidance purpose is, of itself, not sufficient for HMRC to deny a taxpayer its intended tax outcome
Avoidance involving the transfer of assets to Gibraltar
HMRC has opened the contractor loans settlement opportunity to enable recipients of such income to bring their tax affairs up to date. The amnesty applies to tax years up to 5 April 2011, and is open until 9 January 2015.
Chris Davidson reviews the anti-avoidance measures in the current Finance Act and surveys the horizon for the next step in HMRC’s anti-avoidance journey.
FATCA affects the operations of most UK funds. Andrey Krahmal provides a summary