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ANALYSIS

Cutting edge analysis on tax issues.

UK reforms to the permanent establishment rules and the Investment Manager Exemption could reshape the tax treatment for non-resident funds and UK investment managers, write James Anderson and Lorenza De Domenico (Skadden).
David Pickstone and Anastasia Nourescu (Stewarts) consider the Government’s proposed reform of the landfill tax regime and its impact on industry.
Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent practice statement and other measures supporting the greater use of ADR.
This month’s review by Joao Martinho and Gary Barnett (Simmons & Simmons) covers the Court of Appeal decision in Impact Contracting Solutions and two recent cases on the meaning of consideration.
Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s latest policy statements.
Adam Craggs and Liam McKay (RPC) examine the current consultation which could help influence HMRC’s future approach to dispute resolution.
Will AI make tax disputes faster and smarter, or simply more complicated? Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
US developments dominate the headlines in this month’s update by Tim Sarson (KPMG).
Dr Michael Taylor (PwC) considers whether Henderson LJ’s judgment in WTGIL could bring all sorts of intermediary services back within the scope of the VAT insurance exemption.
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