ANTI-AVOIDANCE

Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.

Zoe Andrews

Mike Lane

Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).

Neil Fletcher

Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.

Constantine Christofi

The Supreme Court does strive to find a workable and straightforward interpretation of the law, writes Constantine Christofi (EY).

Jason Collins

Ravikaran Ahlawat

Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.

Ben Elliott

The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).

Susan Dennis

Adam Kay

The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.

Court of Appeal confirms share exchange anti-avoidance rule did not apply.

Jack Gifford

Chris Sanger

The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).