A paradox of the General Anti-Abuse Rule (GAAR) is that it is meant to be narrowly focussed, targeted at abusive tax avoidance schemes and yet some of the threshold tests – “one of the main purposes” and “tax arrangements” - could describe conventional everyday planning.
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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