The ‘threat of recharacterisation’ of transactions where there are no direct comparables is ‘viewed as a significant blocker to corporate activity and growth’, AstraZeneca has claimed.
Transfer pricing enables some companies with overseas ownership to gain an unfair advantage, some participants in a recent survey of larger businesses observed.
Will Mann and Alex Haynes examine the reliance of tax disclosure sections on precedent
There is a consensus that the introduction of a GAAR must be accompanied by a clearance mechanism.
Andrew Goodall reports on the main concerns around the potential introduction of a GAAR
Review of the Budget by James Bullock and Jason Collins
Review of the Budget by Bill Dodwell
Julie Cameron on the implications of HMRC's new toolkits
Your impartial need-to-know guide to the coalition Government's emergency Budget
Where are we now on tax disputes? How do HMRC, business and advisers view the concept of alternative dispute resolution? KPMG's Paul Harrison chairs a round table debate with Dave Hartnett, James Bullock and Kirsten White