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ANTI AVOIDANCE


James Ross (McDermott Will & Emery) reviews recent developments to the hybrid mismatch rules and HMRC’s draft guidance.
 
Sandy Bhogal and Kitty Swanson (Mayer Brown) consider the final output of action 15 of the OECD’s BEPS project and how this will apply to the UK.
 
Jon Thompson (HMRC) reports on the  modernisation agenda and the continued focus on combating tax avoidance.
 

Christina HJI Panayi (Queen Mary University of London) identifies the main EU tax developments in 2016, including the anti-tax avoidance package, decisions in state aid cases, the reform of corporate tax and the relaunch of the common consolidated corporate tax base.

Mark Middleditch (Allen & Overy) examines the themes that have dominated 2016 for the City, including the anti-hybrid rules brought on by the UK’s enthusiasm for BEPS, and looks at 2016’s case law, which shows that HMRC continues its run of success in defeating tax avoidance schemes.

Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.

Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.
 

The proposed corporate offence for failing to prevent tax evasion is now set out in the Criminal Finance Bill, and HMRC has issued revised draft guidance. Jason Collins and Tori Magill (Pinsent Masons) outline the ways a relevant body can manage their exposure to risk.

Mark Middleditch (Allen & Overy) provides this month’s review of tax developments affecting the City.

Gideon Sanitt (Macfarlanes) reviews the decision in Ingenious Media and to what extent HMRC will be held to its duty of confidentiality.
 
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