The general anti-abuse rule

View Tax by content type:

Latest Tax News

Featured Tax content

Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
Read More >
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 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...
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 12th Jan
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 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...
Read More >
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...
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 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...
Read More >
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 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 of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
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
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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 The general anti-abuse rule content

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
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 >
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
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 9th Mar

Popular documents