The Income Tax Appellate Tribunal (ITAT) has held that tax planning carried out within the provisions of the law cannot be classed as a structured transaction for tax evasion purposes, even if the structure saves the company tax.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap