Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
Andrew Roycroft (Norton Rose Fulbright) reviews the decision in the case of Bupa Insurance, which serves as a reminder that a tax avoidance purpose is, of itself, not sufficient for HMRC to deny a taxpayer its intended tax outcome
Avoidance involving the transfer of assets to Gibraltar
HMRC has opened the contractor loans settlement opportunity to enable recipients of such income to bring their tax affairs up to date. The amnesty applies to tax years up to 5 April 2011, and is open until 9 January 2015.
Chris Davidson reviews the anti-avoidance measures in the current Finance Act and surveys the horizon for the next step in HMRC’s anti-avoidance journey.
FATCA affects the operations of most UK funds. Andrey Krahmal provides a summary
David Whiscombe (BKL Tax) reports on the controversial new rules in this year's Finance Act in light of HMRC's new guidance.
Jayne Newton takes a look at where we are now on the new ‘global FATCA’,
James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.