The UK draft Finance Bill 2016 was published on December 9 2015. Sandy Bhogal, head of tax at Mayer Brown in London, focuses on two topics of particular interest – new rules on taxation of performance-linked rewards for investment managers and new anti-hybrid rules arising out of the OECD’s BEPS Project.
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR