ANTI-AVOIDANCE

The decision in Lloyds Bank Leasing illustrates an inherent problem with TAARs which employ purpose-based tests to restrict the availability of tax expenditure reliefs: since the point of tax reliefs is to alter taxpayer behaviour, why then should taxpayers be denied relief for responding accordingly?

William Watson

William Watson (Slaughter and May) considers whether the forthcoming regime TAAR for loan relationships will be less problematic than what currently exists.

Ian Maston

Ian Maston (Mastoni Tax) analyses the measures to simplify the inheritance taxation of trusts.

Nigel Doran

Nigel Doran (Macfarlanes) examines the new anti-avoidance rule

Mitchell R. Kops

Kristin Konschnik

President Obama has proposed a levy for US corporations on profits located abroad, which are not repatriated to the US. Kristin Konschnik and Mitchell R. Kops (Withers) consider the proposals and what effect they may have in practice

David Boneham

David Boneham (Deloitte) summarises the changes arising from the government’s review of the loan relationships and derivative contracts rules.

Robbie Chen

Eloise Walker

Eloise Walker and Robbie Chen (Pinsent Masons) consider the ambit of the new GAAR in the People’s Republic of China

Chris Davidson

Chris Davidson reviews the anti-avoidance measures in the current Finance Act and surveys the horizon for the next step in HMRC’s anti-avoidance journey.

Nigel Doran

Nigel Doran analyses the 147 page tribunal decision, which has attracted so much recent media coverage.

Tina Riches

No safe havens sets out an increasingly tough approach from HMRC on tackling avoidance on offshore income. Tina Riches asks whether it is now time for a proper debate on HMRC’s powers.

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