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Companies

Positive infrastructure

Fair risk

Public perception about the amount of tax paid by business has made tax a global issue for multi-national companies, according to the results of a PricewaterhouseCoopers poll. It is no longer just tax authorities, but customers, pressure groups and other stakeholders, including analysts, who make judgments about whether a company pays a 'fair amount' of tax. As a result, the boards of multi-national companies now recognise that a clear tax strategy is integral to their business strategy.

Artificial losses; CT avoidance; CFCs
PETE MILLER discusses a recent Special Commissioner's decision concerning the tax charge on a company leaving a group.

HMRC help

Assistance from HMRC was provided to the following numbers of small businesses in 2005-06, said Dawn Primarolo in response to a written question:

Small businesses plan; Going online
Interest rates; Large business review; Interventions review; Pre-Budget report 6 Dec; HMRC programme of consultation
GEORGE BULL and CHRIS WILLIAMS consider the implications of fiscal drag for the UK tax system.
MIKE DOWN and JULIE CAMERON consider the increasingly common requests by HMRC in a 'business full enquiry' for records that are held in electronic format.

SIMON WHITEHEAD considers the future of the motive test in the controlled foreign company legislation.

BRIAN WILLIAMS provides a case study explaining some of the intricacies of demergers and why it is imperative to take tax advice early.
It is time for a change with regard to the tax implications of divorce, urges KEVIN SLEVIN.
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