HMRC issued over 600 accelerated payment notices since August to users of marketed tax avoidance schemes, covering tax amounting to £250m. HMRC aims, by the end of March 2016, to have delivered 43,000 such notices, covering £7.1bn.
Heather Self (Pinsent Masons) asks if this the end for the ‘double Irish’ structure
The Irish finance minister, Michael Noonan, announced in his Budget statement on 14 October that the government is putting a stop to ‘double Irish’ corporate tax avoidance arrangements – such as those utilised by multinational corporations Apple and Google – by requiring all companies registered
The government will publish draft clauses to be included in Finance Bill 2015 on Wednesday 10 December 2014, in the week following the Autumn Statement. Consultation on this draft legislation will run until 4 February 2015.
Two of the BEPS deliverables that the OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. Martin Zetter (Macfarlanes) takes a look.
The European Commission has opened an ‘in-depth investigation’ over what it considers to be an ‘unorthodox’ tax deal by Luxembourg with online retailer Amazon.
HMRC is taking an increasingly aggressive approach to disputes involving CTA 2009 s 441 – the targeted anti-avoidance rule on unallowable purpose. Those with genuine commercial borrowing, however, should stand firm, argues Heather Self (Pinsent Masons)
Taxpayers who wish to explore the possibility of resisting follower notices or accelerated payment notices received from HMRC should weigh up their options carefully. Patrick Cannon (15 Old Square) sets these out
Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent updates in the private client arena, including: the proposed new strict liability criminal offence; changes to the LDF; the common reporting standard in the UK; strengthening DOTAS and the VADR; and the Presumption of Death Act.
Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.