FTT

The wrong track or the wrong tax?

Michael Conlon QC (Temple Tax Chambers) considers what can be learnt from the recent Court of Appeal decision.

Liz Wilson

It is difficult to discern any guiding principles on the application of the IR35 rules from these two latest cases, writes Liz Wilson (Squire Patton Boggs).

Heather Self

Heather Self (Pinsent Masons) examines a recent decision that sets out some important principles about the approach to the interpretation of tax treaties.

Heather Self

Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.

Hui Ling McCarthy QC

The role of the Upper Tribunal (UT) in tax appeals has assumed an increased importance, writes Hui Ling McCarthy (11 New Square).

David O'Keeffe

David O’Keeffe (Aiglon Consulting) reviews the tribunal decision in Gas Recovery And Recycle Ltd, which considered whether an anticipatory R&D claim could be made before payment had actually been made.

Adam Craggs

Adam Craggs (RPC) takes a look at the First-tier Tribunal decision in Rotberg, and the extent of the tribunal’s jurisdiction

Abigail McGregor

Eloise Walker

For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers

Chris Morgan

Chris Morgan reviews recent developments in the international tax sphere, including: the two changes to the CFC exemption contained in FB 2014; a summary of the CJEU’s rejection of the UK’s FTT challenge; proposed amendments to the EU’s Parent-Subsidiary Directive; and updates from India and Germany

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