ANTI AVOIDANCE

The FRS 102 treatment of non-commercial loans creates notional finance charges. Finance Bill 2016 excludes these from tax accounts where their inclusion would create an asymmetric tax treatment, writes David Southern QC (Temple Tax Chambers).

Andrew Goldstone

Charlie Sosna

Andrew Goldstone and Charlie Sosna (Mishcon de Reya) review recent private client tax developments that matter.

The European Commission has published its proposals to require multinational companies with annual revenues exceeding €750m to publish country by country reports (CBCR) of their activities in each EU member state. See www.bit.ly/1N63OLI. The...

Expect HMRC to act, writes Jessica Parker (Corker Binning)

Kelly Stricklin-Coutinho

Finance Bill 2016 includes provisions for HMRC to require information on certain state aid issues so that the department can provide it to the European Commission, says Kelly Stricklin-Coutinho (39 Essex Chambers).

HMRC has asked for access to the leaked data – the ‘Panama papers’ – which, it is alleged, reveal large-scale tax evasion and money laundering facilitated by Mossack Fonseca, a law firm based in Panama.

HMRC has published guidance on the new ‘special measures’ regime in Finance Bill 2016 (Sch 19) for those large businesses which persistently engage in aggressive tax planning, or refuse to engage constructively with HMRC.

From 31 March 2016, employers must use new form AAG8 to provide information to HMRC about employees where a tax advantage is expected to arise in connection with their employment as a result of notified arrangements.