COURSE OBJECTIVES: The course examines changing HMRC attitudes and powers and increasing ability to exchange and receive information across borders. HMRC’s approach to ‘international’ enquiries is considered along with strategies for protecting a group from HMRC challenges.
As the tax at stake in such enquiries can be significant, the pros and cons of litigation are considered as is how best to prepare for the litigation process. Finally, the course looks at the impact of EU law and, post Enron, the importance of avoiding conflicts of interest.
COURSE CONTENT
HMRC Schizophrenia
- Helping compliance
- Attacking avoidance
- Risk profiling
Legislative Tools for Enquiries
- Disclosure requirements in return
- Assessments, determinations, appeals
- Documentation requirements
- Information powers
Exchange of Information Between Fiscal Authorities
- Recent changes in UK legislation
- Developments in Double Taxation Agreements
- Tax havens
- Competent authority and arbitration
Favourite HMRC Challenges
- Transfer pricing
- CFC
- Thin capitalisation
- Corporate residence
- Branch/permanent establishment
- Recent developments
Litigation
- Bluff and double-bluff
- Procedures - witness statements, document bundles
- Special Commissioners and beyond
The EU Treaty and Anti Discrimination Articles
- Discrimination and EU Law
- Hoechst- the UK''s largest tax case
- The GLOs
- Current developments
- Towards a common EU tax base?
Tax Risk
- Sarbanes-Oxley
- The EU landscape
- Changing HMRC attitudes
- Where are we now?
WHO SHOULD ATTEND
Finance Directors, Financial Controllers and other finance staff working in large international group companies, as well as professional advisors.
"Very well presented course. Fast and furious. A thorough overview and well researched."
Would you like this course run in-house? Call us on 0207 566 8207 to find out more