HMRC has carried out some spring cleaning on its GAAR guidance. This and other recent developments affecting the City are reviewed by Mark Middleditch (Allen & Overy).
HMRC has carried out some spring cleaning on its 
GAAR guidance. This has for the most part been approved by the independent GAAR advisory panel with effect from 30 January; and it must be taken into account by a court (if a case ever gets that far).
While most of the changes are superficial those made to the ‘Part D’ examples (of when the GAAR will or won’t apply) are worth noting. In the capital gains tax examples the use of a currency option subject to a cap meaning the option...
