David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
Martin Zetter (Macfarlanes) reviews the latest transfer pricing developments, including this month's OECD's public consultation on transfer pricing papers.
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
OUR PICK
HMRC has made welcome changes to the new diverted profits tax, which takes effect from 1 April. As a result, the tax should not disrupt commercially based planning supported by economic substance, writes Shiv Mahalingham (Duff & Phelps).
The Treasury has published its proposed next steps on tackling evasion and avoidance. James Bullock (Pinsent Masons) reviews the detail.
Keith Gregory (NGM Tax Law) answers a query on the taxation of a hive down of a business.
Two changes particularly catch the eye, one welcome and one not so, writes Mike Lane (Slaughter and May).
The meaning of ‘site’ for the aggregate levy
OUR PICK OF THIS WEEK'S CASES
Setting off losses on a trade succession