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ANTI AVOIDANCE


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.

OECD secretary general Angel Gurría welcomed Andorra’s steps to strengthen international tax co-operation, after it became the 60th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.

Helen Adams answers a query on HMRC’s follow-up letters to Swiss account holders under the UK/Swiss tax agreement.

Rob Smith of DLA Piper looks at the UK's new intergovernmental agreements with Guernsey and Jersey

Patrick Stevens offers a defence of eurobonds following the series of reports in The Independent

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