Timothy Lyons QC (Thirty Nine Essex Street) looks at state aid and the European Commission’s investigations into Ireland’s tax ruling over Apple, and Luxembourg’s tax ruling over Fiat.
With this autumn seeing the last political party conferences before the 2015 general election, the three main parties have made promises on tax and spending.
Conservatives:
In a speech to the Securities Industry Conference on 3 October, financial secretary to the Treasury David Gauke MP rejected criticism in international circles that the UK’s patent box facilitates profit shifting.
The Revenue Scotland and Tax Powers Bill received royal assent on 24 September 2014. This Act is the third of three related Acts; the first two Acts introduced land and buildings transaction tax (LBTT) and Scottish landfill tax.
Reasonable excuse and ignorance of the law
Criminal conviction and proceedings in the tax tribunals
Reasonable excuse and late payment
Application to lift a bar to proceedings
Chris Lallemand (Smith & Williamson) discusses some contrasts between the UK implementing legislation for the UK/US IGA, equivalent US regulations and HMRC’s guidance
HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)