ANTI AVOIDANCE

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

Matthew Everett Helen Buchanan Gabrielle Van der Haegen

Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.

Ross Birkbeck

With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).

Oliver Marre

Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.

Robert Langston

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.

Sarah Bond

Helen Buchanan

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Craig Kirkham-Wilson

The APPG on responsible tax proposes criminally prosecuting tax advisers for avoidance planning. Craig Kirkham-Wilson (Simmons & Simmons) explains why the report is based on some misguided assumptions.

Abigail McGregor

Josie Hills

Josie Hills and Abigail McGregor (Pinsent Masons) examine one of the oldest statutory tax avoidance regimes that continues to apply.

Lynnette Bober

Lynnette Bober (Gateley Legal) focuses on some key issues and problem areas which are likely to cross many advisers’ desks this year.

Nigel Giles

Michael Flaherty

Michael Flaherty and Nigel Giles (BDO) provide a refresher guide to these intricate and wide-ranging rules which can easily be overlooked when advising on migration tax planning for individuals.

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