Suchergebnisse

Abstract
Tax matters figured prominently in the Brexit debate. Current signs are, however, that the UK government is not planning the creation of a post-Brexit 'Singapore on Thames' as some had predicted. In fact, we are seeing increases to the main corporation tax rate in response to broader international tax developments and the fiscal upheaval caused by the pandemic. Prior to Brexit, the UK already enjoyed considerable freedom in respect of direct taxes including income tax and corporation tax, but less so for VAT; it has more freedom to change the VAT now, if desired, and has already introduced some relatively small amendments to reflect the new state of play. At this point, the government has exercised its new-found freedoms on tax in quite limited ways—most notably in creating freeports which will benefit from special advantageous customs and tax rules, refocusing R&D tax relief towards activity conducted in the UK, making relatively minor changes to tonnage tax, alcohol duties, and air passenger duty, and removing some narrow EU-focused corporation tax measures. However, these new-found tax freedoms come with new-found restrictions, costs, and challenges for both taxpayers and the UK government. There are significant changes on the tax administration front, which generally complicates matters for HMRC as it will have to rely on less extensive and less convenient treaty and OECD avenues of cooperation. On VAT, teething issues as well as longer-term complications have arisen post-Brexit for businesses and consumers. Provisions remain to control the extent of fiscal state aid, albeit in a less restrictive way under the new subsidy control mechanism in the UK/EU Trade and Co-operation Agreement. The strong overall message is that financial and international pressures and constraints are more important to the direction of tax policy than the fact that the UK has left the EU.

Introduction : a tribute to professor Judith Freedman's outstanding career / Glen Loutzenhiser and Rita de la Feria -- Geoffrey and Elspeth Howe and the path towards independent taxation of husbands and wives : 1968-1980 / Glen Loutzenhiser -- Does an inheritance tax have a future? Practical options to consider / Emma Chamberlain -- Should the suggestion that ownership is a 'myth' have any implications for the structure of tax law? / Edwin Simpson -- Income taxation of small business : towards simplicity, neutrality and coherence / David G Duff -- Principles and practice of taxing small business / Stuart Adam and Helen Miller -- Dependent contractors in tax and employment law / Hugh Collins -- Tackling tax avoidance : the use and growth of statutory 'avoidance' language / Malcolm Gammie -- EU general anti-(tax) avoidance mechanisms / Rita de la Feria -- The concept of abuse of law in European taxation : a methodological and constitutional perspective / Wolfgang Schön -- Fiscal jurisdiction and multinational groups. A perspective from 'political right' / John Snape -- Reflections on the allowance for corporate equity after three decades / Michael P Devereux and John Vella -- The changing patterns of EU direct tax integration / Anzhela Cédelle -- The origins, development and future of zero-rating in the UK / Geoffrey Morse -- Drawing the boundaries of HMRC's discretion / Stephen Daly -- Trends in tax administration / Michael Walpole -- True and fair view and tax accounting / Andrés Báez Moreno.