The National Audit Office has concluded, on the basis of an examination by former High Court tax judge Sir Andrew Park of five large tax settlements, that all five settlements were reasonable and at least one may have been better than reasonable. However, there were concerns about the processes by which the settlements were reached and over poor internal communication of the reasons for settlement which resulted in a loss of confidence in the settlements, both internally and externally. These large settlements are complex and there is no clear answer to what represents the 'right' tax liability. In each case, there was a range of justifiable positions the Department might have taken. The NAO's examination included consideration of whether the settlement in each case was as good as or better than the outcome that might be expected from litigation, taking into account the risks, cost, uncertainties and timescale of that option. It is not clear that all settlements were fully compatible with the Department's Litigation and Settlement Strategy. For instance, there are some disputes where the only possible outcomes are either that the taxpayer owes nothing or that it owes the full amount. In these circumstances, the Department's Litigation and Settlement Strategy does not permit 'splitting the difference'. The Department has acknowledged that its governance processes need strengthening and is introducing new arrangements, including the appointment of an assurance Commissioner, who will approve all large settlements

A wide variety of legal approaches and techniques are presented in detail. Includes 18 country reports - from 14 EU Member States plus Norway, Hungary, Latvia, and the Czech Republic - as well as additional essays on such topics as international tax arbitration, social security conventions, the jurisdiction of international courts, and World Bank/ICSID dispute settlement procedures as all of these may be applied to the resolution of tax disputers.

The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

This is the 10th edition of John Tiley's classic textbook on revenue law, covering the UK tax system, income tax, capital gains tax, inheritance tax and corporation tax, as well as incorporating sections dealing with international and European tax, savings, charities, and - new to this edition - value added tax and stamp duties. The new edition has been comprehensively revised and fully updated with the latest case law, statutory and other developments, including the Finance Act 2021. The book's companion website provides bonus chapters on investment intermediaries, pensions, charities, and the UK's value added tax and stamp duties. The companion website will also supply annual updates to the print edition as well as study questions to help students navigate this complex subject. The book is designed for students taking modules in tax law in the final year of their law degree, or for more advanced courses. It is also a valuable resource for academics and professionals in the field. It provides an account of the rules as well as citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems to give readers a contextual overview of the subject. Accompanying online resources for this title can be found at bloomsbury.pub/tileys-revenue-law. These resources are designed to support teaching and learning when using this textbook and are available at no extra cost.

The Committee have made taxation a key area of focus during this Parliament and have published 20 reports on taxation and made over 100 recommendations to HM Revenue and Customs (HMRC) and HM Treasury aimed at improving HMRC's performance and strengthening confidence in the tax system. The Committee believe they have influenced the debate about multinational companies paying the appropriate amount of tax due, based on their transactions conducted within the UK; exposed serious problems with how the tax planning industry pushes aggressive tax avoidance schemes to businesses and wealthy individuals; helped to reform how HMRC tackles marketed tax avoidance schemes and settles tax disputes with large corporates; and challenged HMRC to provide a better and more even-handed service to customers. The Committee welcome the action that HMRC has taken in response to the recommendations and the progress that has been made. But much remains to be done; for example, HMRC must urgently transform its currently unacceptable levels of customer service. The Committee further welcomes the lead the UK Government has taken in this area on the international stage and call on the next government to continue this work and undertake to tackle both the industry and culture that surrounds and supports tax evasion and aggressive avoidance.