TAARS

The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.

Martin Mann

Martin Mann (Markel Tax) sets out some planning options in view of potential Budget changes.

Robert O'Hare

Jefferson VanderWolk

Robert O’Hare and Jefferson VanderWolk (Squire Patton Boggs) review the operation of the draft rules and speculate on their implementation.

Steve Edge

Dominic Robertson

While the UK’s new digital services tax hogged the limelight in the recent Budget, much less attention was paid to the fact that the proposed extension of withholding tax on royalties paid to tax havens (announced at the previous Budget) was...

Pete Miller

Pete Miller (The Miller Partnership) is critical of HMRC’s long-awaited guidance.

Andrew Evans

Andrew Evans (Geldards) examines the provisions in the Land Transaction Tax and Anti-Avoidance of Devolved Taxes (Wales) Bill.

Karen Cooper

Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.

Jolyon Maugham

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.