In July 2013 the UK introduced a General Anti-Abuse Rule. Having regard to the widespread and international hostility against tax avoidance, this can hardly be considered a surprise. The legislation in the Finance Act 2013 is short but is supplemented by extensive Guidance Notes from HMRC. Unfortunately, although the idea is clear enough, some of the concepts are disconcertingly vague.
Article first appeared in Issue 244, March 2014 of Offshore Investment.