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ANALYSIS
Cutting edge analysis on tax issues.
Transfer pricing compliance: a guiding hand and a warning
Simon Wood
HMRC are clearly not happy with the standard of analysis and documentation
that they are currently seeing, writes Simon Wood (BDO).
Why can’t we love HMRC like we love the NHS?
Jonathan Riley
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
Tax and the City review for October 2024
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Autumn 2024
Harry Smith
Adam Craggs
There has been a steady rise in disputes concerning IHT and SDLT, report
Adam Craggs and Harry Smith (RPC).
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The VAT review for October 2024
Gary Barnett
Jo Crookshank
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers cases concerning payments to acquire ‘credits’, VAT groups
and pension funds.
Officials advise, Ministers decide
Lord Macpherson
What Budget advice is the Chancellor likely to receive from the Permanent
Secretary at the Treasury? We asked former Permanent Secretary
Lord Macpherson for his thoughts.
How to handle tax on residential lease extensions
Chris Holmes
Martin Codd
Chris Holmes (BDO) and Martin Codd (Penningtons Manches Cooper)
consider a more cost-effective route for landlords when considering an
extension of a residential lease with their tenant.
Go to page
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408
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others