The monthly review of tax issues affecting the City, by Mark Middleditch (Allen & Overy).
Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter, including withholding tax consultation, regulatory capital, changes to DOTAS, and penalties for the GAAR.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including new consolidating regulations for country by country reporting; withholding tax exemptions for private placements; mandatory disclosure and CFCs; and banks’ compensation expenditure
HMRC has carried out some spring cleaning on its GAAR guidance. This and other recent developments affecting the City are reviewed by Mark Middleditch (Allen & Overy).
Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Mark Middleditch takes over the reins of our popular monthly briefing on developments affecting the City.
Helen Lethaby takes stock of the changes which have fundamentally changed the rules of engagement between the financial sector and HMRC over the past few years, looking in particular at the impact of the banking code of practice and the GAAR on the behaviour of taxpayers, HMRC and the courts