ANTI AVOIDANCE

We are witnessing a government shakedown of the tax avoidance supply chain, write Richard Woolich and Geoffrey Tack (DLA Piper).

 

New rules will require large UK companies to publish their tax strategies. Researcher Maya Forstater reviews the 61 statements already published by FTSE 100 companies.

 

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).

 

Sandy Bhogal (Mayer Brown) examines a recent tribunal case on whether certain insolvency procedures amount to a change of control for group relief purposes and looks at the potentially significant ramifications. 

 

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.

 

Lynne Rowland (Kingston Smith) explains the proposed changes to DOTAS hallmarks for inheritance tax.

 

Tom Wesel and Zoe Wyatt (Milestone International Tax Partners) review the revised EC’s Anti-Tax Avoidance Directive which will soon be adopted by the European Parliament to ensure a consistent and uniform implementation of BEPS recommendations across the EU.

 

Mark Middleditch (Allen & Overy) reviews recent developments affecting the City.

 

Alasdair Friend (Baker & McKenzie) reviews the recent cases of M Phillips and Tottenham Hotspur Ltd, which represent a reality check against too broad an interpretation of when termination payments flow ‘from’ an employment contract.