TAX POLICY

Conor Quigley QC (Serle Court) argues that the Commission’s approach to state aid seems to misunderstand the whole purpose of tax rulings concerning transfer pricing.

 

Graham Aaronson QC (Joseph Hage Aaronson) presents a personal view of tax avoidance in the UK over the past 100 years, looking at the case law and legislation which developed in the first half century, and the social and economic context in which they evolved.

 

HMRC’s new consultation highlights a number of administrative changes which could make life easier for HMRC and taxpayers. However, a couple of the proposals to change substantive tax charges may have unwanted side effects, writes James McCredie (Macfarlanes).

 

We are witnessing a government shakedown of the tax avoidance supply chain, write Richard Woolich and Geoffrey Tack (DLA Piper).

 

New rules will require large UK companies to publish their tax strategies. Researcher Maya Forstater reviews the 61 statements already published by FTSE 100 companies.

 

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).

 

Sandy Bhogal (Mayer Brown) examines a recent tribunal case on whether certain insolvency procedures amount to a change of control for group relief purposes and looks at the potentially significant ramifications. 

 

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.