The 2014 Finance Bill - Tax avoidance 6 March 2014 0 comments Share Tax treatment of derivative contracts between group companies (‘total return swaps’) and other schemes for the transfer of corporate profits. Double tax relief: technical changes to prevent avoidance schemes. Worldwide debt cap: changes to grouping rules and regulation making powers. Controlled foreign companies (CFCs): changes to prevent profits from existing intra-group lending being diverted out of the UK tax net. Transfer pricing: restriction of claims for compensating adjustments. Further information requirements for ‘high-risk promoters’ of tax avoidance schemes. Strengthening of DOTAS (Disclosure of Tax Avoidance Schemes) information powers. Users of tax avoidance schemes that have been defeated in the courts in cases involving other taxpayers required to settle on that basis or risk a penalty if they cannot establish that the facts of their case are different. Tax to be paid ‘upfront’ in the case of various tax avoidance schemes. Anti-avoidance rules strengthened to counter schemes that seek relief for capital losses of companies against gains on derivatives and other financial products.