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Hmrc
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Hmrc
HMRC
Hely-Hutchinson: was HMRC merely unfair or ‘conspicuously unfair’?
Michael Sherry
What is ‘conspicuously unfair’? The Court of Appeal disagrees with Whipple J, but Michael Sherry (Temple Tax) thinks it was unfair.
Private client briefing for September 2017
Nicola Simmons
Andrew Goldstone
Andrew Goldstone and Nicola Simmons (Mishcon de Reya) provide the monthly update on the taxation of private clients.
The GAAR panel’s first ruling: a reasonable decision?
Heather Self
Heather Self (Pinsent Masons) looks at the implications of the GAAR panel’s first ruling, and considers what we might expect from future rulings.
Supreme Court upholds barring order against HMRC
Gary Barnett
Heather Rowlands
Heather Rowlands and Gary Barnett (Simmons & Simmons) review
BPP Holdings
and its practical implications for the standard of conduct to be expected of HMRC and other public bodies when conducting litigation.
HMRC’s guidance on the company winding up TAARs
Pete Miller
Pete Miller (The Miller Partnership) is critical of HMRC’s long-awaited guidance.
Making tax efficient
Tina Riches
Following significant changes to HMRC’s making tax digital plans, Tina Riches (Smith & Williamson) reviews what is now proposed and what it means for businesses.
The diverted profits tax: two years on
Nick Gurteen
Mario Petriccione
Mario Petriccione and Nick Gurteen (KPMG) consider the impact of DPT for multinationals operating in today’s global business environment and the need to comply with the increasing tax administrative burden.
Ingenious Film Partners 2: whether deductions are capital or revenue in nature?
Lee Ellis
Lee Ellis (Stewarts Law) analyses the tribunal’s supplemental decision that ‘the rights’ to income from the investments made by the Ingenious LLPs were capital in nature and its likely contentious future.
A heretical view of tax simplification
Sam Mitha CBE
Sam Mitha CBE (formerly of HMRC’s Central Tax Policy Group) believes that simplification should be focused on making it easier for taxpayers to comply with the rules, rather than attempting to simplify legislation.
Why I’m challenging Uber
Jolyon Maugham
Jolyon Maugham QC (The Good Law Project) explains why he has issued proceedings in the High Court against Uber to ensure that it pays VAT on supplying transportation services.
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EDITOR'S PICK
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
1 /7
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
,
Mitchell Fraser
2 /7
NICs investment zone reliefs for employers
3 /7
New transfer pricing records requirements
4 /7
UK adopts Pillar Two accounting changes
5 /7
M R Currell Ltd v HMRC
6 /7
Legislation day: draft Finance Bill 2024
7 /7
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
NICs investment zone reliefs for employers
New transfer pricing records requirements
UK adopts Pillar Two accounting changes
M R Currell Ltd v HMRC
Legislation day: draft Finance Bill 2024
NEWS
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Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Treasury Committee calls for systematic review of tax reliefs
CASES
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Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
M R Currell Ltd v HMRC
IN BRIEF
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Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Self’s assessment: Inheritance tax
MOST READ
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