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Anti avoidance
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Anti avoidance
ANTI AVOIDANCE
Temporary non-residence: the anti-avoidance rules
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.
International issues: mitigating controversy
Don Morley
Yvonne Cypher
Basim Khattab
Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.
Haworth: the Supreme Court’s ruling on follower notices
Ben Elliott
HMRC’s attempts to reverse the limitations imposed by the Court of Appeal
backfired, as Ben Elliott (Pump Court Tax Chambers) explains.
Moulsdale and the option to tax
Chris Nyland
The option to tax anti-avoidance rules have always been complex, but do they
make the option to tax an endless roundabout or a one-way street?
Chris Nyland (Gowling WLG) explores.
DAC 6 delayed (a bit)
Ali Kazimi
EU proposes extending the DAC 6 reporting deadlines by 12 weeks.
What’s in store: the Conservative Party’s tax pledges
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) reviews the tax pledges of the new government.
Loan charge review: significant changes afoot
Hugh Gunson
Hugh Gunson (Charles Russell Speechlys) explains where things stand.
European Commission’s tax policy 2019 to 2024: what can we expect?
Jordan Serfati
Nikolaas Van Robbroeck
1 December 2019 marks the start of the new European Commission led by incoming President Ursula von der Leyen. Jordan Serfati and Nikolaas Van Robbroeck (Freshfields Bruckhaus Deringer) consider what's in store for tax policy.
The Supreme Court: ten years on
Michael Conlon KC
A decade of tax decisions examined by Michael Conlon QC (Temple Tax Chambers).
Party political tax proposals
Ami Jack
Ami Jack (Smith & Williamson) sets out a guide to the main political parties’
tax proposals in the run-up to the general election.
Go to page
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224
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
HMRC increase late-payment interest rates
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC