One of the government's themes over the last few years has been to curb what some may see as the excesses of the early 2000s, when there was significantly more aggressive tax planning taking place than there is now. One of the obstacles to curbing this practice is the time and cost that tax litigation takes, which has led to a concern that taxpayers, both in the individual and the corporate sector, have been spinning matters out.

There is little that HM Revenue & Customs (HMRC) can do to combat this; interest rates on overdue tax are not excessive and the courts are rightly concerned to ensure that all parties have an opportunity to make their case. Given this, new measures are to be introduced in summer 2014 to resolve what may be seen as an impasse.

HMRC will have the opportunity to serve a so-called "follower notice", if there has been a similar case decided to the one being disputed. On receipt of this notice, the taxpayer has 90 days to decide what to do: if it concedes, the tax is paid; if the taxpayer decides to fight on, it has to pay the tax (effectively on account), and may also have to pay a penalty of up to 50% of the contested tax.

HMRC will also have the ability to issue notices requiring accelerated payment of tax (but no tax geared penalty) in respect of any open enquiry into a transaction disclosed under the disclosure of tax avoidance schemes (DOTAS) legislation, or where counteraction under the general anti-abuse rule is being taken.

The full impact of the measure is yet to be seen, but it is clear that the government regards it as a significant revenue-raiser. What has been striking is that it has already started to affect corporate transactions such as share sales, where for instance, a tax indemnity may be given. To take account of the new provision, tax indemnities may provide that, if there is a tax dispute for a pre-sale year, which the seller wishes to contest (and for which it would be liable to reimburse the buyer), the seller will be forced to pay any tax demanded on account if an advanced payment notice is received from HMRC.

Sellers in this position will have to think carefully about the mechanics of any payment and how to deal with its potential reimbursement. Any repayment would be made to the taxpayer company and not to the seller. They will also have to consider how best to ensure that the repayment will be made to the seller in the future, when the company may have changed hands several times.

From the buyer's perspective, the position is probably simpler, although if there is to be security for tax claims, such as an escrow account, it needs to be sure that it can access that to finance any tax that is required to be paid.

Outside of these proposals, the corporate sector does not escape anti-avoidance measures. One is a very widely drawn measure seeking to prevent groups from shifting profits around the group. In a provision remarkable for its brevity, a group cannot shift profits if tax is the main purpose, or one of the main purposes, of the arrangements. This may seem unobjectionable, but if HMRC seeks to apply a main purpose test to a transaction, it is often difficult for the taxpayer to prove a negative.

These provisions are also unusual for anti-avoidance provisions, as there is no other statutory filter to prevent their application. It will be interesting to see if HMRC is prepared to concede that there should be a carve-out for transactions entered into in the ordinary course of business or a similar gateway. We may end up with guidance stating that this is HMRC's intention but, by virtue of being non-statutory guidance, it will be difficult for companies to have confidence that they can rely on it.

In terms of other developments, it was largely a case of watching this space, other than for the banking or oil and gas sectors, where there continue to be specific changes, not least, yet again, to the bank levy (see "Bank levy: further consultation" Bulletin, Taxation, this issue).

It is clear that the Organisation for Economic Co-operation and Development's (OECD) base erosion and profit shifting (BEPS) initiative will mean changes to the UK tax regime, probably starting in 2015. On the same day as Budget 2014, the Treasury published a paper setting out the UK's position. This was a mixture of a defence that, largely, the UK was ahead of others (such as on controlled foreign companies), a statement that it may look at some changes (including, worryingly, interest deductibility, although a robust defence of the UK's general position is to be hoped for) and will certainly look at some changes (such as on hybrid instruments).

The publication of the Treasury's paper coincided with the publication of the OECD's discussion documents on treaty abuse, hybrid mismatch arrangements and the digital economy, each of which canvases options for change (see "BEPS project: discussion documents" Bulletin, Taxation, this issue). It is yet to be seen which specific solutions will be adopted, but some changes will be made and their impact will be felt by the corporate sector, particularly if they have international operations, or market or sell their products or services outside of the UK.