AVOIDANCE

High Court permits rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules.

The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).

Helen Buchanan

Sarah Bond

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Josie Hills

Abigail McGregor

Josie Hills and Abigail McGregor (Pinsent Masons) examine one of the oldest statutory tax avoidance regimes that continues to apply.

Sarah Bond

Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.

Oliver Marre

Oliver Marre (5 Stone Buildings) discusses the TOAA provisions in the light of the Fisher decision and asks: what should taxpayers do now to avoid penal income tax charges on offshore transfers?

Heather Self

Hannah Hurley

Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.

George Peretz KC

In May, the EU General Court delivered two judgments on fiscal state aid. George Peretz QC (Monckton Chambers) explains why they still matter in the UK in light of the UK’s proposed state aid regime.

Rebecca Seeley Harris

Rebecca Seeley Harris (RE Legal Consulting Ltd) explains the need for a comprehensive and constructive policy to protect both worker’s rights and revenues for the exchequer and the steps taken so far to regulate the industry.