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ANTI AVOIDANCE


Jonathan Fletcher Rogers considers whether Aberdeen Asset Management signals the end of tax avoidance on employee benefits.

The OECD has launched a consultation on a series of minor changes to the OECD Model Tax Convention. The majority are minor editorial or clarificatory changes, but they do include additional commentary on:

The Sixth Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes is being held on 21–22 November 2013 in Jakarta, Indonesia.

The Select Committee on Statutory Instruments (SCSI) has concluded that the International Tax Compliance (United States of America) Regulations, SI 2013/1962, may be ultra vires. These regulations bring into effect the intergovernmental agreement made on 12 September 2013.

Helen Lethaby reviews recent developments affecting the City, including profit deferral under AIFMD, compensating adjustments, new DOTAS rules and the Ingenious Media case.

The Supreme Court has found in favour of HMRC in the Cotter case, overturning the previous decision of the Court of Appeal.

The Cayman Islands has become the first overseas territory to sign a FATCA-style intergovernmental agreement with the UK for automatic exchange of information for tax purposes. Agreements have already been signed with the UK’s Crown dependencies: Jersey, Guernsey and the Isle of Man.

Richard Carson comments on the Upper Tribunal decision in HMRC v Lloyds TSB Equipment Leasing on a targeted anti-avoidance rule.

Paul Radcliffe on the news that the OECD is developing a model competent authority agreement

HMRC has published a new spotlight about an employee bonuses tax avoidance scheme involving restricted securities.

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