Tax News Highlights: February 2022

In this podcast, Zoe Andrews and Tanja Velling consider the increasing interest in the link between tax and climate action in particular in light of the High Court decision in R (oao Cox & Others) v The Oil And Gas Authority & Others, the new public interest business protection tax which is proposed to be enacted as part of the current Finance Bill, HMRC’s revised draft guidance on the large business notification of uncertain tax treatment and HM Treasury’s consultation on the UK’s implementation of Pillar Two.

They also cover the European Commission’s proposal for a directive to prevent the misuse of shell entities which is commonly referred to as Unshell or ATAD3, considering in particular its potential impact on the UK, as well as the publication of the revised, 2022 edition of OECD’s transfer pricing guidelines, and the Court of Appeal’s decision in the Embiricos case on partial closure notices which confirms that the regime cannot be used to force a judicial determination of a preliminary legal issue.