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Corporate Tax Risk and Tax Avoidance: New ApproachesJudith FreedmanUniversity of Oxford - Faculty of Law; Oxford University Centre for Business Taxation Geoffrey T LoomerSchulich School of Law, Dalhousie University; Oxford University Centre for Business Taxation John VellaUniversity of Oxford - Faculty of Law; Oxford University Centre for Business Taxation April 1, 2009 British Tax Review, Vol. 1, pp. 74-116, 2009 Oxford Legal Studies Research Paper No. 13/2009 Abstract: The relationship between tax authorities and large corporate taxpayers is a concern world-wide as can be seen from the 2008 OECD Study into the Role of Tax Intermediaries. In the United Kingdom, HMRC have been developing a risk rating approach to tax risk management as part of their Review of Links with Large Business. The approach is designed to promote an enhanced relationship between HMRC and the taxpayer, based on trust and transparency. The objectives include the improvement of resource allocation and the encouragement of companies to consider their position so as to achieve the benefits of low risk rating, which may involve altering their tax planning strategy. In addition, new approaches to tax avoidance legislation such as targeted anti-avoidance rules and principles-based legislation are being introduced or considered. This article discusses a survey of tax directors in which the authors used detailed tax planning scenarios to investigate the views of tax directors on the impact and success or otherwise of these new approaches. The views of tax directors are only one factor in judging the success of these developments, but given that one aim of current tax policy is an enhanced relationship with corporate taxpayers, directors’ views are significant in assessing the progress being made. The article analyses these views and comments on these new approaches to tax risk management.
Number of Pages in PDF File: 44 Accepted Paper SeriesDate posted: April 16, 2009 ; Last revised: April 23, 2009Suggested CitationContact Information
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