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OFFSHORE
Ask an expert: Offshore trusts and trustee borrowing
Julie Howard
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
VAT grouping disputes: the implications of HSBC
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.
International business operating models: the tax issues
Hannah McKenzie
Gavin Orpwood
Louise Keegan
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Tax transparent property funds
Toby Price
Alexandra Hawkins
Toby Price and Alexandra Hawkins (Deloitte) discuss the SDLT treatment of
tax transparent funds investing in UK real estate.
Jersey’s economic substance rules
Rupert Lee
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
The FTT’s recent approach to transfers of assets abroad
Rory Mullan
Rory Mullan (
Old Square Tax Chambers) examines two
cases that demonstrate the importance of establishing the
fundamental requirements of the TOAA code before a
charge can be imposed.
Private client review for July 2019
Jonathan S. Betesh
Andrew Goldstone
Andrew Goldstone and Jonathan S. Betesh (Mishcon de Reya) review the
latest tax developments affecting private clients.
Tax and the City review for June 2019
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Image rights payments are earnings
Kevin Offer
Kevin Offer (Hardwick and Morris) examines the tribunal decision in
Hull City AFC (Tigers) Ltd v HMRC
that provides the first judicial guidance since the
Sports Club
case on how to approach the question of whether a payment for image rights constitutes earnings.
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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
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James Burton
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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
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Treasury Committee calls for systematic review of tax reliefs
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M R Currell Ltd v HMRC
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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
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Self’s assessment: Inheritance tax
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