ANTI AVOIDANCE

Andrew Goldstone and Alexander Makinson (Mishcon de Reya) review the latest tax developments affecting private clients.

Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC. 

Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

It is now 18 months since the entry into force of the UKs corporate criminal offences of failing to prevent the facilitation of tax evasion. This milestone coincides with the publication of Ipsos Moris research report, as part of the...

Helen Adams (BDO) considers the extent of HMRC's powers on discovery in the light of recent case law.