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ANALYSIS

Cutting edge analysis on tax issues.

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).
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.
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.
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. 
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.
Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the proposals for a new UK stamp tax on securities regime.
While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).
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).
Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).
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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