Anti-avoidance

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Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
What is an intangible fixed asset?Part 8 of the Corporation Tax Act 2009 (CTA 2009) is a specific corporation tax regime that applies exclusively to...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Anti-avoidance content

Practice notes
Disclosure of tax avoidance schemes—IHTFORTHCOMING CHANGE relating to Finance Bill 2021–22: Finance Bill 2021–22 (which is expected to be enacted as...
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23rd Jul
Practice notes
Penalties for enablers of defeated tax avoidance schemesFORTHCOMING CHANGE relating to Finance Bill 2021–22: Finance Bill 2021–22 (which is expected...
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23rd Jul
Practice notes
Disclosure of tax avoidance schemes—procedureFORTHCOMING CHANGE relating to Finance Bill 2021–22: Finance Bill 2021–22 (which is expected to be...
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22nd Jul
Practice notes
Disclosure of tax avoidance schemes—VAT and other indirect taxes (DASVOIT)FORTHCOMING CHANGE relating to Finance Bill 2021–22: Finance Bill 2021–22...
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22nd Jul
Practice notes
Promoters of tax avoidance schemesSTOP PRESS relating to Finance Bill 2021: Finance Act 2021 contains a number of measures, taking effect from 10 June...
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22nd Jul
Practice notes
Follower noticesSTOP PRESS: Finance Act 2021 has, with effect from Royal Assent, reduced the maximum level of a standard follower notice penalty to...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 6th Jul
Practice notes
The general anti-abuse rule (GAAR)STOP PRESS: Finance Act 2021 (FA 2021) has, in relation to tax arrangements (within the meaning of the GAAR) entered...
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23rd Jun
Practice notes
The GAAR procedureSTOP PRESS: Finance Act 2021 (FA 2021) has, in relation to tax arrangements (within the meaning of the GAAR) entered into at any...
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23rd Jun
Practice notes
Ramsay in reverseLexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the...
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22nd Jun
Practice notes
Ramsay and composite transactionsLexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice...
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16th Jun
Q&As
Should I consider whether Ramsay applies to my transaction?The Ramsay principle is an approach to statutory interpretation that has been developed by...
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6th Jun
Practice notes
Accelerated payment noticesThe Finance Act 2014 (FA 2014) introduced the concepts of an accelerated payment notice (APN) and a partner payment notice...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 5th Jun
Practice notes
Disclosure of tax avoidance schemes—SDLTThis Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to stamp...
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5th Jun
Practice notes
Disclosable cross-border tax arrangements—DAC 6FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements...
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5th Jun
Practice notes
Ramsay and prescriptive statutory languageLexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this...
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5th Jun
Practice notes
Disclosure of tax avoidance schemes—VAT (before 1 January 2018) [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.This...
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5th Jun
Practice notes
Ramsay—reality and legal formLexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note....
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5th Jun
Practice notes
Ramsay as a guide to statutory constructionLexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this...
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5th Jun
Practice notes
The GAAR advisory panelThe general anti-abuse rule (the GAAR):•counteracts (by the making of adjustments on a just and reasonable basis by HMRC or the...
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5th Jun
Practice notes
Disclosure of tax avoidance schemes—income tax, corporation tax, CGT and NICsThis Practice Note describes the rules on the disclosure of tax avoidance...
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5th Jun

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