The government will publish draft clauses to be included in Finance Bill 2015 on Wednesday 10 December 2014, in the week following the Autumn Statement. Consultation on this draft legislation will run until 4 February 2015.
Two of the BEPS deliverables that the OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. Martin Zetter (Macfarlanes) takes a look.
The European Commission has opened an ‘in-depth investigation’ over what it considers to be an ‘unorthodox’ tax deal by Luxembourg with online retailer Amazon.
HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)
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