Anti-avoidance

Navigate the complexities of tax law enforcement with clear strategies and insights. This topic gives your team comprehensive guidance on counteracting tax avoidance schemes, ensuring compliance and mitigating risks. Delve into practical tips, case studies, and legislative updates to fortify your expertise in anti-avoidance measures.

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Disclosure of tax avoidance schemes Follower and accelerated payments notices Hybrid mismatches Tax anti-avoidance rules The general anti-abuse rule The Ramsay principle

Latest Tax News

FTT allows recovery of input tax on directly and immediately linked costs (Victoria Oil & Gas plc v HMRC)

FTT allows recovery of input tax on directly and immediately linked costs (Victoria Oil & Gas plc v HMRC)

Tax analysis: In Victoria Oil & Gas plc v HMRC, the First-Tier Tax Tribunal (FTT) allowed the appeal in part. It decided that, in principle, Victoria...

UT upholds travel expenses relief for cabin crew’s mandatory Heathrow hotel stays between linked transatlantic return trips (HMRC v British Airways plc)

UT upholds travel expenses relief for cabin crew’s mandatory Heathrow hotel stays between linked transatlantic return trips (HMRC v British Airways plc)

Tax analysis: In HMRC v British Airways plc, the Upper Tribunal (UT) dismissed HMRC’s appeal, holding that mandatory hotel stays provided to cabin...

Updated: Apply for an agent services account

Updated: Apply for an agent services account

HMRC has updated its guidance on applying for an agent services account to state that approved anti-money laundering supervision must be in place...

Tax weekly highlights—1 October 2026

Tax weekly highlights—1 October 2026

This week's edition of Tax weekly highlights includes: (1) analysis of the Upper Tribunal’s decision in Jumpman Gaming concerning remote gaming duty...

Featured Tax content

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation payments

VAT treatment of damages and compensation paymentsA damages or compensation payment may attract VAT. This depends on exactly what the payment is for....

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)

The double taxation treaty passport scheme (DTTP scheme)The double taxation treaty passport scheme (DTTP scheme) enables a borrower to apply for and...

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?

What are capital allowances and capital expenditure?What are capital allowances?Capital allowances are the means by which tax relief is given for some...

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the tenant to pay or provide any amount in respect of a VAT supply to the tenant...that amount will be deemed to be exclusive of VAT...and the tenant shall pay a sum equal to that VAT’, will this be sufficient to charge the tenant VAT? Is there any case law in this area?

If the words ‘exclusive of VAT’ are omitted from the definition of annual rent, but there is a VAT clause stating: ‘Where this lease requires the...

Practice notes

Direct tax treatment of damages and compensation payments

Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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30th May
Practice notes

Residential service charges—VAT implications

Residential service charges—VAT implicationsThis Practice Note is about the VAT treatment of residential service charges.Service charges payable to...
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Produced in partnership with Martin Scammell
13th Oct
Practice notes

Commercial service charges—VAT implications

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
13th Oct
Practice notes

Taxation of UK LLPs

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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30th May
Practice notes

Qualifying charitable donations and excess management expenses

Qualifying charitable donations and excess management expensesAll companies within the charge to corporation tax can deduct qualifying charitable...
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30th May
Practice notes

Amortisation of intangible fixed assets

Amortisation of intangible fixed assetsWhere a company acquires (or otherwise incurs capitalised expenditure upon) an intangible fixed asset that...
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30th May
Practice notes

The Budget and Finance Bill process

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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30th May
Practice notes

Tax treatment of reorganisations of share capital

Tax treatment of reorganisations of share capitalThis Practice Note is about the meaning of a reorganisation for tax purposes, and the tax treatment...
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2nd Jun
Practice notes

Capital gains—intra-group asset transfers

Capital gains—intra-group asset transfersCompanies which form a group for capital gains purposes are able to transfer assets to one another free of...
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30th May
Practice notes

VAT treatment of intermediaries, agents and disbursements

VAT treatment of intermediaries, agents and disbursementsFor VAT purposes, an intermediary is a person who makes arrangements for, or facilitates, a...
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Produced in partnership with Mark Rowbotham MA FCILT of Portcullis ISC
13th Oct
Practice notes

Taxation of private equity funds—the investors

How are investors in a private equity fund taxed on their share of the profits?This Practice Note sets out how the investors in a typical UK private...
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Produced in partnership with Emily Clark of Travers Smith
13th Oct
Practice notes

Tax and offshore funds—what is an offshore fund?

Taxation of offshore funds—what is an offshore fund?Background to the offshore funds rulesSpecific tax legislation dealing with offshore funds was...
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Produced in partnership with Michael Alliston of Norton Rose Fulbright
13th Oct
Practice notes

Partnerships and capital gains

Partnerships and capital gainsThis Practice Note is about the capital gains tax and corporation tax on chargeable gains treatment of UK general...
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2nd Jun
Practice notes

Tax considerations on a loan agreement—the tax gross up clause

Tax considerations on a loan agreement—the tax gross up clauseIt is standard market practice for loan agreements (also known as facility agreements),...
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Produced in partnership with Eloise Walker of Pinsent Masons
13th Oct
Q&As

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a share structure identical to the target company?

For stamp duty relief under section 77 of the Finance Act 1986 (FA 1986) to apply, must the acquiring company in a share for share exchange have a...
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2nd Jun
Practice notes

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)

Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)UK real estate can be held as an investment through an offshore...
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2nd Jun

Popular documents

Late payment penalties—inheritance tax

Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal

If a beneficiary signs a deed of disclaimer of their share of an estate and the estate pays their legal fees, will that count as a PET against their estate?A disclaimer is the refusal of a gift prior to acceptance. The refusal of the gift must take place before the beneficiary accepts any benefit

Strike out—making an application to strike out a statement of case

Strike out—making an application to strike out a statement of caseA strike out order can be made either following an application by the parties or on the court's own initiative. This Practice Note deals with the scenario of the order being made following a party's application.Making an application

Template for regulatory references given by SMCR firms and disclosure requirements

Template for regulatory references given by SMCR firms and disclosure requirements[Insert addressee details]Dear [insert name][It is our understanding that [insert name of prospective employee] [was an employee of yours between the dates of [insert dates as appropriate] OR is a current employee of