More than £25 billion of tax was ‘under consideration’ in HMRC’s Large Business Service (LBS) enquiries at 31 March 2011, but the department emphasised that the estimate did not represent tax owed or unpaid.
HMRC are seeking views on how to ensure that genuine losses incurred in business or employment are relieved against income or gains while deterring taxpayers from entering into tax avoidance arrangements intended to exploit the reliefs.
The study group considering the merits of a introducing a general anti-avoidance rule has reached consensus on the potential advantages of a GAAR for the UK, and what concerns such a rule would need to ‘address and allay’.
When I finally put down my dog-eared copy of the last instance decision in MCashback, my office screamed the same eerie silence that had greeted Ronaldinho's freak goal in 2002 to end the nation's World Cup hopes.
Jonathan Peacock QC and Michael Ripley consider what significance lies in a contention that ‘money goes around in a circle’ after the decision in Tower MCashback and identify what exactly was decided in Ensign Tankers, MacNiven and BMBF v Mawson in this regard
Ian Sandles examines the impact of the new rules on the financial sector
Helen Lethaby provides this month's update on tax issues affecting the City, including consultation resulting from Basel III, recent accounting changes, the overlooked decision in Audley and an update on the GAAR study
HMRC are offering employers who have utilised Employee Benefit Trusts and similar arrangements the opportunity to resolve outstanding enquiries without recourse to litigation. Adam Craggs considers whether employers should take up this opportunity.