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CORPORATE TAXES
Legislation day: draft Finance Bill 2024
A Lexis+ UK Tax report of the key announcements with additional practitioner comment.
Holding HMRC to a statement
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
Pillar Two: compatibility of the UTPR with double tax treaties
Bezhan Salehy
Sarah Ling
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
International aspects of demergers
Chris Holmes
Ross Robertson
Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for.
HMRC’s approach to purpose-based enquiries
Helen Buchanan
Sarah Bond
Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
The electricity generator levy: an introduction
Hiral Bhatt
Hiral Bhatt (Alvarez & Marsal) examines how the new levy will work and uncovers some uncertainties yet to be resolved.
Tax and the City review for April 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
Terminating an acquisition mid-completion
Eloise Walker
As contract terminations proliferate in uncertain economic times, Eloise Walker (Pinsent Masons) looks at the tax issues arising from terminating an acquisition before it completes.
Tax and the City review for March 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Earn-outs in M&A transactions: working hard for capital treatment?
Tomás McGrath
Dominic Robertson
Tomás McGrath and Dominic Robertson (Slaughter and May) discuss
pitfalls and practical tips when considering earn-outs in M&A transactions.
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EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
Read all