Anti-avoidance

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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...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
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...
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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:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
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...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
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...
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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...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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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...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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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...
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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...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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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....
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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...
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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...
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9th Nov

Most recent Anti-avoidance content

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...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 9th Apr
Practice notes
FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...
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9th Apr
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...
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9th Apr
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...
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9th Apr
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...
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9th Apr
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...
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9th Apr
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...
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9th Apr
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...
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9th Apr
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 >
9th Apr
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...
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9th Apr
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 >
9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Act 2021 will, with effect from Royal Assent, reduce the maximum level of a standard follower notice penalty to 30% (down...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 6th Apr
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...
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1st Apr
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 >
1st Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021, published on 11 March 2021, contains a number of measures, taking effect from Royal Assent, to take further...
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26th Mar
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to take further action against those who...
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26th Mar
Practice notes
FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to strengthen the...
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25th Mar
Practice notes
FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 (FB 2021) introduces a new information notice that HMRC may issue to anyone it...
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25th Mar
Practice notes
FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 (FB 2021) introduces a new information notice that HMRC may issue to anyone it...
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25th Mar
Practice notes
The Scottish general anti-avoidance rule (Scottish GAAR) aims to protect revenue through counteracting tax avoidance arrangements, and is intended to...
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Produced in partnership with Andrew Ford of Barr & Ford Limited 9th Mar

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