Where will the focus lie for tax disputes in 2016? In the corporate tax arena, transfer pricing is likely to be the highest profile area, partly because of engagement with HMRC over the diverted profits tax which the department regards as a tool to ensure that appropriate transfer pricing policies are in place. Expect also to see more on long running issues, such as the EU group litigation orders, EBTs and the SDLT anti-avoidance measure in FA 2003 s 75A. We can also expect more on when HMRC can be held to its published guidance. More generally, a hot technical issue in major tribunal appeals is the relationship between the tribunal rules and the High Court’s civil procedure rules (CPR) – and the extent to which the CPR applies in the tribunal.
Rupert Shiers (Hogan Lovells) comments on key areas where HMRC will focus in 2016 and where the law regulating HMRC and tax disputes will be developed.
Where will the focus lie for tax disputes in 2016? In the corporate tax arena, transfer pricing is likely to be the highest profile area, partly because of engagement with HMRC over the diverted profits tax which the department regards as a tool to ensure that appropriate transfer pricing policies are in place. Expect also to see more on long running issues, such as the EU group litigation orders, EBTs and the SDLT anti-avoidance measure in FA 2003 s 75A. We can also expect more on when HMRC can be held to its published guidance. More generally, a hot technical issue in major tribunal appeals is the relationship between the tribunal rules and the High Court’s civil procedure rules (CPR) – and the extent to which the CPR applies in the tribunal.
Rupert Shiers (Hogan Lovells) comments on key areas where HMRC will focus in 2016 and where the law regulating HMRC and tax disputes will be developed.