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Uncertainty and risk
Key points
- Transactional activity has been disrupted by the coronavirus pandemic.
- Insurance is being sought for more unusual tax risks.
- Uncertainty from delays to tax rulings and clearances.
- Risks may arise in distressed mergers and acquisitions.
- Potential issues with corporate restructurings.
Tax insurance provides an insight into taxpayer sentiment – what concerns taxpayers what activities are they undertaking and what will they do next? For example concerns may relate to a particular subjectivity in the law: does a ‘business’ exist for the purposes of the Ramsay v CRC [2013] STC 1764 case? Is a liquidation caught by the ‘phoenix companies’ targeted anti-avoidance rule (TAAR)?
With Brexit on the horizon and various challenging tax changes coming into force – IR35 for the private sector and the latest EU directive on administrative co-operation (DAC6) spring to mind – 2020 was always going to be an interesting year. In the first month or...
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