The Draft Finance Bill 2013 (HL 139) evaluates the draft Finance Bill which, following detailed consultations based on the findings of an independent study group, includes proposals for a General Anti-Abuse Rule (GAAR), narrowly targeted at abusive transactions which fail a stringent 'double reasonableness' test. The provisions also include the formation of an Advisory Panel to agree guidance and give its opinion on the application of the double reasonableness test to a given set of tax arrangements. Most agree the narrow focus was appropriate. Some witnesses argued that HM Revenue and Customs (HMRC) should set up a clearance system to reduce uncertainty about where the GAAR would apply. Many witnesses were very concerned at the application of the GAAR to transactions involving inheritance tax planning. The Bill also includes an Annual Residential Property Tax Package (ARPT) which is part of a package of measures to address Stamp Duty Land Tax avoidance by

The Government proposes introducing legislative tests to determine if an Limited Liability Partnership member is an employee or truly a partner. Failing these tests would make the member liable for income tax and National Insurance Contributions (NIC) as an employee and the LLP would pay employer NICs. Nearly all the evidence received by the Committee was that the legislative tests failed to achieve the policy objective. Many suggested that existing case law could be used instead. A delay in implementation until April 2015 would allow for further consultation to target the legislation better and for businesses to adapt to the changes. The Committee also raised concerns that the proposed changes to tax arrangements for LLPs would apply only to UK registered LLPs and not those conducting business here but formed outside the UK. The Committee is content in principle with proposed measures to counter shifting of profit to corporate members of partnerships to minimise tax liability and highlights the extent of this practice in the Alternative Investment Fund Management (AIFM) Sector. But the Committee wants to see the legislation drafted more precisely. And it is concerned that the Government's revised estimates of the tax yield from these measures, and particularly the additional £1.92bn in 2015-2019 from the AIFM sector, show that the Government's original estimates of tax yield were very wide of the mark.

The Finance Bill Sub-Committee of the Economic Affairs Committee has met most years since 2003 to examine selected aspects of the year's Finance Bill or, since 2013, draft Finance Bill. The FBSC began its inquiry into the draft Finance Bill 2016 in January and chose to focus on two cross-cutting issues: the extent to which measures proposed in the draft Bill contribute to the simplification of the personal tax system; and their impact on the compliance burdens of taxpayers. In considering these two broad issues, the inquiry concentrated on three areas in the draft Bill: the clauses reforming the taxation of savings income and dividends; those providing new powers for HMRC to issue Simple Assessments of an individual's tax liability; and those establishing the Office of Tax Simplification (OTS) on a statutorybasis.

Policymakers and program managers are continually seeking ways to improve accountability in achieving an entity's mission. A key factor in improving accountability in achieving an entity's mission is to implement an effective internal control system. An effective internal control system helps an entity adapt to shifting environments, evolving demands, changing risks, and new priorities. As programs change and entities strive to improve operational processes and implement new technology, management continually evaluates its internal control system so that it is effective and updated when necessary. Section 3512 (c) and (d) of Title 31 of the United States Code (commonly known as the Federal Managers' Financial Integrity Act (FMFIA)) requires the Comptroller General to issue standards for internal control in the federal government.

The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Taxes Management Act 1970 (UK) The Law Library presents the official text of the Taxes Management Act 1970 (UK). Updated as of March 26, 2018 This book contains: - The complete text of the Taxes Management Act 1970 (UK) - A table of contents with the page number of each section

Despite the improvement in the public finances, this year's Autumn statement is fiscally neutral and locks in lower spending by reducing departmental budgets for 2014-15 and 2015-16 by 1.1% but excluding local government, Security & Intelligence Agencies and HMRC. The Government will: cap the Retail Prices Index in business rates to 2% in 2014-15 and extend the doubling of Small Business Rate Relief to April 2014; will provide a business rate discount of £1,000 in 2014-15 and 2014-16 for retail properties with a rateable value of up to £50,000 and a 50% discount from business rates for new occupants of previously empty retail premises for 18 months; abolish National Insurance Contributions for under 21 year olds on earnings up £813 per week; remove cap on higher education student numbers; announce further reforms to make the most of the UK's science base; introduce a new tax relief for shale gas, and increase support for employee ownership and the creative industries; improve the UK's infrastructure with the National Infrastructure Plan 2013; and take further action to increase housing supply and support home ownership. Fuel prices will be frozen and the impact of policies on energy bills will be reduced. The average increase in rail fares will capped. Married couples & civil partners will be allowed to transfer £1,000 of their income tax personal allowance to their spouse where neither is a higher rate taxpayer.

The exploding use of derivatives in the last two decades has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This very thorough book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes greatly elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: – basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' – concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and - tackling derivatives tax arbitrage effectively in anti-avoidance legislation. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.

The OBR's forecast for GDP growth in 2012 is -0.1 percent and is projected to pick up in every year of the forecast. Public Sector Net Borrowing is forecast to fall by 1.0 percent of GDP in 2012-13 and in subsequent years of the forecast. Public Sector Net Debt is expected to be 79.9 per cent of GDP in 2015-16 before falling to 77.3 per cent by 2017-18. This Statement sets out a further £6.6 billion package of savings in the spending review period, made up from welfare, Official Development Assistance (ODA) and departmental current spending. A £5.5 billion of additional infrastructure will be funded, including in new roads, science and free schools and academies. There will be a further 1 per cent cut in the main rate of corporation tax from April 2014, to 21 per cent and a significant temporary increase in the Annual Investment Allowance from £25,000 to £250, 000 for two years. A greater proportion of growth-related spending will be devolved to local areas and a Business Bank will be created to deploy £1 billion of additional capital and enable UK Export Finance to provide up to £1.5 billion in loans with a package of reforms to promote export. The Government will: increase the basic State Pension by 2.5 percent; create an HM Revenue & Customs unit dedicated to tackling offshore tax evasion; introduce of the UK's first General Anti-abuse Rule; develop significant new information disclosure and penalty powers; and close off tax loopholes. Lifetime allowances for pension contributions will be reduced.