GAAR: A Practical Approach by Patrick Cannon – Third Edition

The latest edition of GAAR: A Practical Approach by Patrick Cannon updates the book to include analysis of the first opinions of the Advisory Panel and the most recent version of HMRC’s GAAR Guidance.

Further updates include a new Chapter 4 covering what might be called the weaponisation of the GAAR by means of the specific GAAR penalty in section 212A FA 2013 and the presumption of carelessness in GAAR related matters for the purposes of inaccuracy penalties in Schedule 24 FA 2007.

A new Chapter 9 has been included to deal with the Penalties for Enablers of Defeated Tax Avoidance regime in Schedule 16, F(No.2)A 2017 which can apply when a scheme has been counteracted by HMRC using the GAAR.

Chapter 3 (Counteraction by HMRC) has been updated for the introduction of provisional counteraction, pooling and binding notices and the generic referral of tax arrangements by FA 2016.

Also included are updates to the text for other relevant developments relating to recent Supreme Court Judgments in UBS AG and DB Group Services -v- HMRC and Murray Group Holdings.

A copy of the book can be purchased here.