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COMPLIANCE


The UK has published draft regulations adopting an EU directive that promises faster resolution of double taxation disputes between member states.
Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in Rossendale that demonstrates the potential general application of the Ramsay approach, but clearly shows its limits as a means of countering avoidance.
Jason Collins (Pinsent Masons) highlights the measures that personal service companies need to put in place to minimise the effect of not complying with the IR35 rules.
Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.
Ashley Greenbank and Penny Van den Brande (Macfarlanes) consider the UK tax consequences for businesses considering moving assets or functions out of the UK, whether by a change of residence of a UK company, the insertion of a new, non-UK, holding company or the relocation of specific assets and functions
Ryan Bebbington and Daniel Sladen (PKF-Francis Clark) provide a reference guide to the rules and highlights the key areas to consider for those advising SMEs

Julian Feiner (Clifford Chance) discusses the taxpayers' resounding victory at the Upper Tribunal in the company residency case of Development Securities plc and others v HMRC

Groups will need to review their existing arrangements and consider appropriate jurisdictions for new investments, write Emily Osborne and Hilary Barclay (Stephenson Harwood).

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

Ian Goodwin (Mazars) discusses recent developments and the compliance issues facing employers.
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