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This article examines the scope of FA 2003 s. 75A and whether it could apply to transactions entered into with no tax avoidance purpose.

This article discusses the Statutory Residence Test provisions contained in the draft Finance Bill and explains that, compared to the Government’s earlier proposals they had became longer and more complex…

An article which considers the Statutory Residence Test as proposed in the draft Finance Bill and the pitfalls which it contains.

This article provides a detailed analysis of the Statutory Residence Test as set out in the Finance Bill and explains that the Government had failed to create a simple and…

This article examines the draft anti-abuse rule (the ‘GAAR’) published in a Consultation Document and its implications for tax advisers

This article considers whether the proposed SRT would fulfil its purpose and highlights various anomalies.

In this article the application of the draft SRT is considered by way of a case study. This concludes that the proposed legislation is neither clear or unambiguous.

This is a book review of a practitioner’s text on the subject of tax avoidance.

In this article the application of the provisions of IHTA 1984 ss. 74A-74C are considered as they apply to excluded property trusts and non-domiciled settlors.

In this article the proposed SRT is critically examined to determine whether it is ‘transparent, objective and simple to use’.

This article considers by way of a case study the proposed anti-avoidance legislation now found in IHTA 1984 ss. 74A-74C where interests in settled property in offshore trusts are acquired.

This article examines the application of the proposed general anti-abuse rule to the availability of main residence relief and the incorporation of a business to reduce a tax liability.

This article considers the grandfathering provisions found in the Inheritance Tax DOTAS rules and HMRC’s guidance on them.

A consideration by Simon McKie on whether tax avoidance is wrong.

In this article the proposed GAAR is examined to determine whether its application is to abusive transactions only or to a wider ranging set of transactions.

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