A Critical Evaluation of the UK Taxation System and Internationalisation

Attitudes towards Tax Avoidance in recent years

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.

Required:

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.

Second class:

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.  

Third class:

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.  

ASSIGNMENT MARKING GUIDE

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.

A discussion of what is meant by tax avoidance

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

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

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

Formation of a logical conclusion following a well reasoned argument.

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.

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.

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.