Heather Self (Pinsent Masons) asks if this the end for the ‘double Irish’ structure
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
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
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.
The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.
The debate on tax is being distorted by poor reporting in national media and grandstanding from members of the PAC. It is time for advisers to take a more active role in better informing the public on tax, writes Pete Miller.
The cut in the top rate of income tax from 50% to 45% set up a tax avoidance opportunity. The numbers suggest plenty took advantage of it, David Smith reports
Few advisers will be surprised at the First-tier Tribunal’s rejection of the highly artificial ‘blue box’ tax planning scheme. David Whiscombe examines the decision which provides a useful summary of the current position on the Ramsay principle
Nigel Doran analyses the 147 page tribunal decision, which has attracted so much recent media coverage.
Tom Scott considers the topical issue of whether or not the UK can now be considered a tax haven, and the global tax legislative changes we can expect to see