The Tax Avoidance Schemes (Penalty) (Amendment) Regulations, SI 2010/2743, prescribe increased maximum daily penalties for failure to comply with certain disclosure obligations where a tax tribunal has made a disclosure order.
The number of disclosures of avoidance schemes has fallen in the six months to 30 September 2010, according to provisional figures released by HMRC. Fifty-six disclosures were made, including 48 relating to direct taxes and NICs. There were 99 disclosures in the six months to 31 March 2010.
The way that tax interacts with Finance Transformation programmes is changing rapidly from being a peripheral end-user to being a key business partner. Rachel Taylor examines the drivers for this change and what Tax Directors should be considering in relation to their own Finance Transformations
Generating sustainable value and avoiding unpleasant surprises increasingly requires a clear strategy, aligned with your corporate goals, and supported by a robust framework for the management of tax risk, reports Mark Kennedy
The ‘threat of recharacterisation’ of transactions where there are no direct comparables is ‘viewed as a significant blocker to corporate activity and growth’, AstraZeneca has claimed.
Transfer pricing enables some companies with overseas ownership to gain an unfair advantage, some participants in a recent survey of larger businesses observed.
Will Mann and Alex Haynes examine the reliance of tax disclosure sections on precedent
There is a consensus that the introduction of a GAAR must be accompanied by a clearance mechanism.
Andrew Goodall reports on the main concerns around the potential introduction of a GAAR
Review of the Budget by James Bullock and Jason Collins