CPD Hours Level
Seminar 6 IntermediateInformation
Accreditation Information
SRA Competency B


This course will provide you with an understanding of all the fundamental UK domestic and international (post BEPS) anti-avoidance tax rules relevant to income tax, CGT, corporation tax, VAT and SDLT.

Lessons to be learnt from failed tax planning arrangements and key anti-avoidance 'red flags' relevant to structuring transactions and the scope of 'acceptable' tax planning will be examined.

If you advise individuals, trustees and corporations operating in the UK and international arena then this course is for you.

What You Will Learn

This course will cover the following:

  • Tax planning versus tax avoidance: the acceptable limits
  • DOTAS: disclosure obligations: nature and extent
  • Interpretation of legislation: scope and application of Ramsay, Barclays Mercantile Business Finance Ltd v Mawson, Carreras Group Ltd v The Stamp Commissioner
  • Current anti-avoidance case law and recent trends
  • Main purpose/object tests: nature and construction
  • Unallowable purpose test
  • Expenditure incurred
  • Circularity of fund flows
  • Commerciality
  • Key direct tax anti-avoidance rules in context:
    • Targeted anti-avoidance rules (TAARs)
    • Transactions in securities: s682 to s713 of the 2007 Income Tax Act / post FA 2016
    • Transactions in land: post FA 2016
    • Transfer of assets abroad: ITA 2007
    • Entrepreneurs' relief: 'relevant avoidance arrangements'
    • Loss relief restrictions
    • Interest deductibility restrictions
    • General Anti-Abuse Rule: scope
  • Key indirect tax anti-avoidance rules in context:
    • Abuse of rights, Halifax, Pendragon Plc, Ocean Finance
    • Split supplies
    • Partial exemption: 'fair and reasonable'
    • Hallmarks of avoidance
  • Key SDLT anti-avoidance rules in context:
    • Section 75A FA 2003, Project Blue Limited
    • Group relief: main purpose
  • Key anti-avoidance concepts in double taxation agreements: beneficial ownership, subject to tax provisions, anti-treaty shopping provisions
  • Diverted Profits Tax: scope and interaction with other rules
  • Key tax avoidance principles post BEPS: review of the OECD Multilateral Convention on Tax Treaty Related measures to prevent Base Erosion and Profit Shifting
  • Safe harbours and exceptions to anti-avoidance rules
  • Role of clearance
  • Tax planning: lessons to be learnt from case law
  • Common implementation errors arising from tax avoidance arrangements
  • Buying a company with historic tax avoidance arrangements: how to protect the purchaser
  • Dealing with HMRC challenges to tax avoidance: practical perspectives

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Seminar | 12.06.2019

London | 9:30am - 5:15pm

Anti-Avoidance Tax Rules - UK Principles & Beyond BEPS

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9:30am - 5:15pm
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Discounts are available for multiple places and if you have 5 or more people interested in this course and would like to discuss holding it in your area or on an in-house basis then please email us at information@mblseminars.com
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