When the UK Supreme Court ruled in favour of HM Revenue and Customs (HMRC) in the Tower MCashback decision in May concerning capital allowances, many tax practitioners lamented what the Court seemed to be saying about the tax avoidance arguments that HMRC may advance during a hearing. The decision comes at a time when HMRC is entering into more enquiries and disputes with corporate taxpayers. Erin Kelechava investigates whether the case is yet another sign of a new era defined by more contentious relationships between Revenue and taxpayers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers