ANTI AVOIDANCE

Simon Yeo reflects on HMRC’s recent guidance on how the SDLT anti-avoidance in FA 2003 s 75A applies to financing around distributions of property to shareholders

The Times reported (13 January) that James Anderson – manager of Scottish Mortgage Investment Trust, one of Britain’s biggest shareholders in Amazon, Google, Facebook and Apple – warned the companies ‘not to be so aggressive in avoiding UK corporation tax’.

David Whiscombe examines Boyle, a First-tier Tribunal decision on a contractor loan scheme of the kind currently being challenged by HMRC

The Financial Times has reported (15 December) Vodafone as saying that businesses must open up their affairs to more public scrutiny.

A look back on some of this year’s key developments:

• Mike Lane takes stock on the BEPS project, and what to expect;
• David Quentin gives an outspoken view on how business and tax professionals responded to the tax avoidance debate in 2013;
• Adam Craggs sums up some cautionary tales for advisers in the light of the BAA, Mehjoo and Cotter decisions this year.

HMRC has modified its consultation proposals on disguised employment, dropping the employment status test to focus instead on the economic tests around remuneration, capital contribution and control to determine whether a member is an employee.

The draft Finance Bill has proposed more measures to tackle false self-employment. Andrew Goodall reports.

Andrew Goodall has a look at the TUC report on the deficiencies in the general anti-abuse rule (GAAR) and says we need to be clear about the type of avoidance that the GAAR is designed to address

Your guide to the key measures

The Trade Union Congress (TUC) this week released its report, The deficiencies in the general anti-abuse rule, criticising the government’s GAAR as ‘so poorly designed that it will allow 99% of tax avoidance to continue’.