The draft Finance Bill 2012 provisions include legislation for new CFC and patent box regimes but otherwise includes few surprises. Aaronson’s study group concludes that a GAAR is necessary to tackle ‘egregious’ tax planning and proposes a statutory formula designed to identify the same. The Court of Appeal is unpersuaded by the employment-income-todividend alchemy in PA Holdings. The Canadian courts find against the taxpayer in a marginal GAAR case. It is all systems go across the Channel, including surprise hikes in rates of French stamp duty on share transfers.
