Looking for avoidance

KEY POINTS

• UK/Luxembourg double tax agreement.
• Use of franchises.
• Engaging people through service companies.
• Tax strategies using limited-recourse loans.
• HMRC have changed their tune.

I am not sure whether I want to join the tax avoidance debate. It does not seem to me that it is being conducted in the real world. Much of what is being said or written seems to me to have little to do with tax avoidance as most tax practitioners understand the term.

When we have an MP namely Frank Field appearing to advocate mob rule as a solution to tax avoidance during a backbenchers’ debate on corporate tax avoidance it seems clear that informed opinion (assuming one looks on MPs as opinion formers) has become so remote from reality that...