The First-tier Tribunal has finally given a decision on the loan relationships unallowable purpose test, 15 years after its introduction. Matthew Hodkin discusses whether it was worth the wait.
The tax gap was £35bn in 2009/10, according to HMRC’s estimate released today. The department has revised its £42bn estimate for the previous year to £39bn.
An avoidance scheme in which the recipient of a manufactured overseas dividend (MOD) seeks a credit for UK income tax where ‘no actual UK income tax has been paid’ is to be blocked with effect from 15 September.
Estimating the tax gap provides an important tool in understanding the causes of non-compliance and helping HMRC to focus on ways of reducing it, Dave Hartnett told the Treasury Sub-Committee yesterday.
The government has confirmed that an avoidance scheme designed to accelerate first year allowances is to be blocked with effect from 12 August 2011.
The government has abandoned a consultation – due to close in less than a fortnight – on proposed measures to counter tax avoidance ‘exploiting’ double tax treaties.
Corporate loss carry-forwards are now as high as 25% of GDP in some countries, according to the OECD.
HMRC are to publish an update to last month’s ‘tax treaties anti-avoidance’ consultation in the light of concerns raised by business and tax advisers.
Draft regulations creating a charge to national insurance contributions on amounts chargeable to income tax under the disguised remuneration rules have been published for comment.
ITEPA 2003 Part 7A (employment income provided through third parties) was inserted by FA 2011.