TAX POLICY ADMINISTRATION

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).

 

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.

 

Adam Craggs (RPC) reviews the decision in Mabbutt, which serves as an important reminder of the essential elements of a valid notice of enquiry into an individual’s specific tax return.

 

Josh Lom and Perminder Gainda (Herbert Smith Freehills) consider the decisions in McQuillan and Castledine, where the tribunals took different approaches to the meaning of ‘ordinary share capital’.

 

Corporates are facing the regulatory scrutiny once reserved for banks. Gideon Sanitt (Macfarlanes) considers the treatment of the costs of such investigations.

 

Chris Morgan (KPMG) assesses the latest developments that matter in the international tax arena.