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A review of cases that have gone to the GAAR panel: what can we learn?
The UK General Anti Abuse Rule (GAAR) was introduced in April 2013 (and applies to arrangements entered into on or after...
Will it be a safe landing?
The transfer of assets abroad provisions exist to counteract tax avoidance achieved by means of a relevant transaction w...
Keeping your confidences
In the context of tax disputes, privilege is commonly understood as referring to the fundamental legal right which allow...
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A legislative flood
An ever increasing deluge of ink on the statute books is dedicated to quashing any perceived tax avoidance before it eve...
A new dawn
The ADR deficit It is well known that the Tribunal system is under increasing pressure and often overwhelmed with cases...
Born in the USA
With the recent increase in international enforcement activities undertaken by the US Internal Revenue Service (IRS) and...