Next week’s Finance Bill will include the new general anti-abuse rule (GAAR) which is expected to come into effect in June or July 2013. It is perhaps a measure of the changing political climate over the past year that the GAAR, which was initially very controversial in some quarters, is now widely regarded as necessary … Continue reading The GAAR
The Autumn Statement 2012 contained a number of announcements of interest to individuals and small and medium-sized enterprises, but there was comparatively little of relevance to large companies and banks. The main eye-catching announcement to affect corporates is the further 1% cut to the headline rate of corporation tax – the rate will reduce from 24% for the current year, to 23% from 1 April … Continue reading Corporation tax rate cut again, but pressure on corporate tax avoidance will only increase
The Budget did not signal any changes to the Transfer Pricing rules which is most welcome at this time as there is a packed schedule of initiatives over the next 12 months for transfer pricing at the OECD level, chief of which is the review and likely re-write of Chapter VI (Special Considerations for Intangible Property) and Chapter VIII … Continue reading Increasing reliance on Transfer Pricing principles?
A stamp duty land tax (SDLT) anti-avoidance scheme that has been widely used by residential purchasers has been stopped by measures announced in the Budget. The scheme broadly involved the purchaser granting an option simultaneously with completion of the acquisition of the property to an unconnected third party, exercisable many years in the future. The … Continue reading More on the sub-sale and other general SDLT anti-avoidance measures
Following recent publicity surrounding a certain UK bank avoiding tax on a purchase of own debt the odds could only have shortened on the introduction of a GAAR. But it might be that the die was cast somewhat earlier when the Court of Appeal found for the taxpayer in the case of Mayes. In the context of a highly engineered … Continue reading Towards a General Anti-Abuse Rule