The short answer is, 'different things to different people'. And that is one of the reasons why the issue is not going to be resolved any time soon; at least, not sensibly. Let's be absolutely clear about this, "tax avoidance" is not the same as "tax evasion". Tax evasion is, essentially, the process of evading [...]
The Government published the long awaited consultation document on the Above The Line (ATL) Credit for R&D yesterday. Here is my initial analysis of the proposals. Before looking at the proposed structure, it is worth looking at David Gauke's foreword. In this, he states that the Government "would like a system for supporting R&D which [...]
So George Osborne has again stated that the Government intends to introduce an Above The Line (ATL) R&D credit, following consultation. Although we are still waiting for the publication of the consultation document - I understand from HMT that they are aiming to issue it next week - the wording of the announcement causes me [...]
George Osborne delivered his 2012 Budget earlier this afternoon; from my perspective, there were few surprises. The Finance Bill is due to be published next week, when we will have the chance to review the detailed legislation. We are also waiting for two important consultation documents covering the above the line R&D credit and the [...]
It seems a reasonable question to pose at the moment - would a GAAR have stopped Barclays' recent attempts to save tax? Clearly, I don't have access to the full details of Barclays' planning but from what I do know and what I can surmise from that, it seems likely that a GAAR along the [...]
I was at a meeting earlier this week where there was a very interesting discussion around tax policy and consultations. Almost inevitably, the discussion eventually turned (albeit briefly) to the question of a GAAR and whether we should have one. So, should we have one? That's a very emotive question but before we can answer that question, [...]
I've just been talking with the FD of a company that is (in my opinion) almost certainly incurring significant amounts of expenditure on qualifying R&D. What's more, it's pretty clear that they've been doing so for several years. The directors of the company are working hard to grow it in a competitive market. Which begs [...]
You cannot fail to have noticed that just about every mobile device/tablet manufacturer is suing at least one of their competitors at the moment. None of them seems to be free from some form of legal action in what is starting to look a little like a merry-go-round of lawsuits! My concern with all of [...]
That is to say, revised guidance has been prepared (in draft) but here’s the problem - it remains un-finalised and, more importantly, unpublished. What that means, of course, is that the current guidance, published in the Corporate Intangibles Research & Development (CIRD) manual at CIRD81350, doesn’t accurately reflect HMRC’s current thinking. Given that HMRC seems [...]
There has been (and continues to be) a lot of consultation around various aspects of the UK tax regime lately. Apart from the fact that sometimes it feels as though it's all happening at once, that has to be a good thing. Most recently, I have been involved in consultations on the CFC reform, the [...]