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Stitch up? Lord Hodge, in last week’s highly anticipated judgement in the Rangers / Murray Holdings / RFC2012/Big Tax case, stated that the legislative code in relation to the taxation of earnings was not ‘a seamless garment but… a patchwork of provisions’. Of course, most interested parties will know that 
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Background The APN (including Follower Notices) legislation was introduced a couple of years ago to essentially prevent tax scheme users from dragging their feet on tax disputes. Initially, the rules were designed to avoid situations in which having secured judgement against one user of a particular scheme, others who had 
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Over the course of the last few months, the affairs of some of football’s biggest clubs and players have found themselves forced onto the back foot by one of the game’s most difficult opponents: the taxman. Once again, soccer’s finances have been scrutinised by those who believe that it’s not 
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Background The APN (including Follower Notices) legislation was introduced a couple of years ago to essentially prevent tax scheme users from dragging their feet on tax disputes. Initially, the rules were designed to avoid situations in which having secured judgement against one user of a particular scheme, others who had 
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Derry v HMRC The Court of Appeal handed down its judgement in the case of R on the application of Derry v HMRC on 20 June. It is a case that could be significant for individuals who have participated in marketed tax arrangements and have made claims to carry back 
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If you’ve paid even passing attention to print and broadcast media over the last few weeks, you will perhaps be aware that we are currently in close season for many of the world’s leading football leagues. This is the time when clubs consider their squads for the next campaign, spending 
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Financial transparency – The danger in showing one’s cards? The world’s financial system charges headlong towards transparency. There seems to be a beneficial ownership register being created or proposed for everything at the moment. Company ownership, residential property…toenail clippings. We reminisce of the good old days where FATCA, CRS and 
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Numerous cases involving marketed tax avoidance arrangements are still making their way through the courts and tribunals. Where HMRC has won those cases and all avenues of appeal on the part of the affected taxpayers have either been exhausted or abandoned, it has begun using the powers conferred on it 
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