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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
Andrew Goldstone
Nicola Simmons
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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18
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others