Anti-avoidance

View Tax by content type:

Featured Tax content

Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
Read More >
Produced in partnership with Martin Wilson 9th Nov
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
Read More >
Produced in partnership with Gary Barnett, Martin Shah and Simmons & Simmons 9th Nov
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
Read More >
9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
Read More >
Produced in partnership with Zoe Feller of Bird & Bird 9th Nov
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
Read More >
Produced in partnership with Martin Wilson 9th Nov
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
Read More >
Produced in partnership with Eloise Walker of Pinsent Masons 9th Nov
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
Read More >
9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
Read More >
Produced in partnership with Philip Rutherford 9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
Read More >
9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
Read More >
9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
Read More >
9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
Read More >
Produced in partnership with Martin Shah 9th Nov
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
Read More >
9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
Read More >
9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
Read More >
9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
Read More >
9th Nov

Most recent Anti-avoidance content

Practice notes
The UK’s disclosable arrangements rules implement EU Directive 2018/822, also known as DAC 6, or the EU Mandatory Disclosure Regime (EU MDR). The...
Read More >
30th Nov
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2020 on 11 March 2020, the government is taking forward further measures to reduce the scope for...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2020, Finance Bill 2020–21 will include provisions to strengthen anti-avoidance rules, including the...
Read More >
29th Nov
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
29th Nov
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.This Practice Note describes the rules on the disclosure of arrangements for...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–21 will contain a number of measures, taking effect from Royal Assent, to strengthen the POTAS rules. These...
Read More >
29th Nov
Practice notes
This Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to income tax, corporation tax, capital gains tax...
Read More >
29th Nov
Practice notes
The Finance Act 2014 (FA 2014) introduced the concepts of an accelerated payment notice (APN) and a partner payment notice (PPN) to help combat tax...
Read More >
Produced in partnership with Keith Gordon of Temple Tax Chambers 29th Nov
Practice notes
On 17 July 2014, the Finance Act 2014 (FA 2014) introduced the concept of a follower notice. It is a further weapon in HMRC’s armoury in its battle...
Read More >
Produced in partnership with Keith Gordon of Temple Tax Chambers 29th Nov
Practice notes
This Practice Note describes the rules on the disclosure of tax avoidance schemes (DOTAS) applying to stamp duty land tax (SDLT).The procedural...
Read More >
29th Nov
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
29th Nov
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
29th Nov
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: With effect from Royal Assent to the Finance Bill 2021 (FB 2021), it is expected that:•HMRC will be able to apply the GAAR to a...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–21 will introduce a new information notice that HMRC may issue to anyone it suspects of being involved in the...
Read More >
29th Nov
Practice notes
The general anti-abuse rule (the GAAR):•counteracts (by the making of adjustments on a just and reasonable basis by HMRC or the taxpayer)•tax...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: With effect from Royal Assent to the Finance Bill 2021 (FB 2021), it is expected that:•HMRC will be able to apply the GAAR to a...
Read More >
29th Nov
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
Read More >
29th Nov
Practice notes
FORTHCOMING CHANGE: Finance Bill 2020–21 will introduce a new information notice that HMRC may issue to anyone it suspects of being involved in the...
Read More >
29th Nov
Practice notes
The Scottish general anti-avoidance rule (Scottish GAAR) aims to protect revenue through counteracting tax avoidance arrangements, and is intended to...
Read More >
Produced in partnership with Andrew Ford of Barr & Ford Limited 29th Nov

Popular documents