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In the first of two articles examining the close companies rules, Hannah Manning and Ross McGregor (Travers Smith) explain why it should not be assumed that a company is not close without looking carefully at the relevant legislation.
The newly reformed tax on carried interest will subject carried interest to the payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland & Ellis) set out some of the key practical considerations.
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.
Principled positions often adopted by HMRC can have the practical effect of avoiding or otherwise delaying judicial scrutiny of their decision-making process, write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
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