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ANALYSIS
Cutting edge analysis on tax issues.
Judicial review: does the Court of Appeal’s decision in Murphy offer taxpayers a glimmer of hope?
Adam Craggs
Liam McKay
Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).
Back to basics: Section 260 holdover relief
Paul Townson
Sophie Mehta
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
HMRC’s approach to purpose-based enquiries
Helen Buchanan
Sarah Bond
Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
The first 100 days as a head of tax
Peter Mason
Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days.
The VAT review for June 2023
Bryn Reynolds
Gary Barnett
Bryn Reynolds and Gary Barnett (Simmons & Simmons) examine the latest developments affecting VAT, including two CJEU decisions and a significant change to the Retained EU Law Bill.
Modernising stamp duty: are we nearly there yet?
Emily Szasz
John Tolman
Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the
proposals for a new UK stamp tax on securities regime.
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
Rhiannon Kinghall Were
While a coordinated roll-out of rules was once an aspiration, the reality is
anything but, explain Ashley Greenbank and Rhiannon Kinghall Were
(Macfarlanes).
Knocking on IRS’s door: the new accruals framework for carried interest
Eli Hillman
Linus Ostberg
Relief for double taxation of carried interest now needs to be found on
the other side of the Atlantic. The new accruals regime helps to make this
possible, write Eli Hillman and Linus Ostberg (KPMG).
International review for May 2023
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
The reserved investor fund regime: restricted or unrestricted, that is the question
Martin Shah
Martin Shah (Simmons
& Simmons) reviews the proposed reserved investor fund regime, while
Melville Rodrigues (Apex Group) says why it is needed.
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EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
Read all