UK Tax Avoidance: HMRC & Global Reactions.

Attitudes towards Tax Avoidance in the UK

Answered

Learning Outcome Assessment

1) Critically evaluate the structure and operation of the system of taxation in the UK and the interaction with foreign tax systems (internationalisation).

2) Demonstrate a critical awareness of the key factors which influence the development of taxation strategy requiring consideration of ethical responsibility.

In recent years there has been an increased focus on unacceptable tax avoidance involving individuals as well as multi-national corporations.

The UK government has had to react to the issue of tax avoidance especially given increased public scrutiny on the issue.

Critically evaluate the attitudes towards tax avoidance in recent years and analyse HM Revenue & Customs approach to managing the risk of tax avoidance in the form of the General Anti-Abuse Rule (GAAR). Furthermore critically evaluate Base Erosion and Profit Shifting (BEPS) and government reaction both in the UK and Internationally.

Secondary Research Level HE6 - It is expected that the Reference List will contain between fifteen to twenty sources. As a MINIMUM the Reference List should include three referenced academic journals and five academic books.

First class:

Students will provide an in-depth appraisal of attitudes towards tax avoidance in recent years demonstrating excellent critical reasoning skills. Focused and justified analysis will be provided in respect of the need for anti avoidance rules and HMRC’s response in respect of the GAAR guidance and analysis of BEPS. Extensive research demonstrating use of a wide range of current secondary research sources will be evident. Academic style and referencing will be excellent.

Students will provide an effective appraisal of attitudes towards tax avoidance in recent years demonstrating sound critical reasoning skills. Justified analysis will be provided in respect of the need for anti avoidance rules and HMRC’s response in respect of the GAAR guidance and the BEPS. Research demonstrating use of a wide range of current secondary research sources will be evident. Academic style and referencing will be good.

Students will provide a satisfactory appraisal of attitudes towards tax avoidance in recent years demonstrating some critical reasoning skills. Considered analysis will be provided in respect of the need for anti avoidance rules and HMRC’s response in respect of the GAAR guidance and BEPS. Research demonstrating use of a range of current secondary research sources will be evident. Academic style and referencing will be fair, with the report being produced to a satisfactory standard.

Marks are awarded for structure and referencing of the essay as well as for the extent of the literature review, depth of analysis/evaluation and formation of a conclusion.

1. A discussion of what is meant by tax avoidance 10

2. An evaluation of changes in UK attitudes to tax avoidance and reasons why there is increased public scrutiny 10

3. An assessment of the extent to which a GAAR is necessary in the UK. 30

4. Critical appraisal Base Erosion Profit Shifting (BEPS) and UK and International governments reaction to counter BEPS 30

5. Formation of a logical conclusion following a well reasoned argument. 10

Structure/referencing/bibliography

		Relevance	Knowledge	Argument/Analysis	Structure	Presentation	Written English	Research/Referencing
Class I (Exceptional Quality)	80%+	As for Class 1(70-79%) but exceptional work
Class I (Exceptional Quality)	70-79%	Directly relevant to title. Addresses most or all of the implications and assumptions of the title.	Demonstrates an excellent knowledge/understanding of theory and practice for this level. Demonstrates the ability to identify and critically appraise the most important issues, themes and questions.	Makes creative use of appropriate arguments and/or theoretical models. Contains some distinctive or independent thinking. A comprehensive evaluation of the material resulting in clear, logical and illuminating conclusions.	Coherently articulated and logically structured. An appropriate format is used.	The presentational style & layout is correct for the type of assignment. Effective inclusion of figures, tables, plates (FTP).	A very well written answer with standard spelling and grammar. Style is clear, resourceful and academic.	All sources accurately cited in the text and a very extensive reference list in the correct style is provided.
Class II/i (Very Good Quality)	60-69%	Directly relevant to title. Addresses some of the implications of the issues addressed by the title.	Demonstrates a comprehensive knowledge/understanding of theory and practice for this level. Demonstrates the ability to identify and critically appraise key issues, themes and questions.	Uses appropriate arguments or theoretical models. A sound evaluation of the material resulting in clear and logical conclusions.	For the most part coherently articulated and logically constructed. An appropriate format is used.	The presentational style & layout is correct for the type of assignment. Effective inclusion of FTP.	Well written with standard spelling and grammar. Style is clear and academic.	All sources accurately cited in the text and a wide range of appropriate references cited in the reference list in the correct style.
Class II/ii (Good Quality)	50-59%	Generally addresses the title and its implications, but sometimes addresses irrelevant issues.	Demonstrates a good knowledge/understanding of theory and practice for this level, through the identification and critical appraisal of some key issues, themes and questions.	Provides a coherent argument, but some loss of focus and consistency. Some issues lack clarity, or theoretical models expressed in simplistic terms. Adequate critique, with some descriptive or narrative passages. Conclusions are fairly clear and logical.	Adequate attempt at articulation and logical structure. An acceptable format is used.	The presentational style & layout is correct for the type of assignment. Inclusion of FTP but lacks selectivity.	Competently written with minor lapses in spelling and grammar. Style is readable and mainly academic.	Most sources accurately cited in the text and an appropriate reference list in largely the correct style is provided.
Class III (Satisfactory Quality)	40-49%	Some degree of irrelevance to the title. Superficial consideration of the issues.	Demonstrates adequate knowledge/understanding of theory and practice, with appraisal of some basic issues, themes and questions.	An argument is evident but lacks clarity and coherence in places. Issues are only broadly stated. Some analysis with descriptive or narrative passages. Conclusions are not always clear or logical.	Some attempt at articulation and logical structure. An acceptable format is used.	The presentational style & layout is largely correct for the type of assignment. Inappropriate use of FTP or not used where clearly needed to aid understanding.	Generally competent writing although intermittent lapses in grammar and spelling pose obstacles for the reader. Style limits communication and tends not to be academic.	Some relevant sources cited. Some weaknesses in referencing technique.
Borderline Fail	35-39%	Some significant degree of irrelevance to the title is common. Onlythe most obvious issues are addressed at a superficial level and in unchallenging terms.	Demonstrates weaknesses in knowledge/understanding of theory practice for this level. Key issues not identified or appraised.	A basic argument is presented, but largely descriptive or narrative in style with contradictory analysis. Conclusions are neither clear nor logical.	Poorly structured. Lack of articulation. Format deficient.	For the type of assignment the presentational style &/or layout is lacking. FTP ignored in text or not used where clearly needed.	Deficiencies in spelling and grammar make reading difficult. Simplistic or repetitious style impairs clarity.	Limited sources and weak referencing.
Fail	<34%	Relevance to the title is intermittent or missing. The topic is reduced to its vaguest and least challenging terms.	Demonstrates a lack of basic knowledge of either theory or practice for this level, with little evidence of understanding.	Severely limited arguments. Descriptive or narrative in style with no evidence of critique. Conclusions are sparse.	Unstructured. Lack of articulation. Format deficient.	For the type of assignment the presentational style &/or layout is lacking. FTP as above.	Poorly written with numerous deficiencies in grammar, spelling, expression and style.	An absence of academic sources and poor referencing technique.