Tax Avoidance

This 2nd edition of Tax Avoidance contains a unique perspective on the new UK General Anti-Abuse rule including comparisons with GAARs in overseas jurisdictions, interaction with existing laws and principles and practical examples. Tax Avoidance also explains key areas of detailed tax avoidance legislation and case law from a UK perspective, updated to include commentary on the Finance Act 2013 changes to the transfers of assets abroad provisions. Within this new edition you will find: 1. Updated analysis of the Ramsay principle and how it has evolved over the last three decades and the difference between the Ramsay principle and the Sham Doctrine 2. Analysis of the key avoidance provisions, including the recently introduced Transfers of Income Streams provisions and the Sales of Occupation Income and Transactions in Land rules 3. Expert discussion of the recently amended Transactions in Securities rules 4. Detailed coverage of the Transfers of Assets Abroad provisions, updated for the Finance Act 2013 changes 5. In depth discussion of the EU principle of Abuse and its application in both direct and indirect tax in the UK 6.
Unique and detailed analysis of the UK GAAR together with the GAAR Guidance and related procedures Introduction; Transfer of Assets Abroad; Transactions in Land; Transfer of Income Streams; Sales of Occupation Income; Transactions in Securities; Ramsay: A principle of statutory interpretation or a judge made rule?; Sham; The Concept of Trade in a Tax Avoidance Context; Abuse; General Anti- Abuse Rule