CORPORATION TAX

Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).

Andrew Howard

Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.

David Whiscombe

David Whiscombe (BKL) reviews the first GAAR Panel decision in favour of the taxpayer and argues that the underlying legislation is long overdue for repeal.

Sarah Squires

Sarah Squires (Old Square Tax Chambers) considers how the rebasing rules apply to a recent non-resident's plans to sell UK buy-to-let properties.

Paul Farey

Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim.

Helen Coward

Helen Coward (Charles Russell Speechlys) examines the decision in The Tower One St George Wharf Ltd concerning the SDLT group relief anti-avoidance rule.

Angela Savin

Michael Brady

Angela Savin and Michael Brady (KPMG Law) review the impact of a recent Supreme Court ruling.

Zoe Andrews

Mike Lane

The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.

Paul Pritchard

Football may not be coming home, but there is always tax to consider. Paul Pritchard (FTI Consulting) reviews the tax issues on player transfers, including the reinvestment relief on players, employment tax issues with buyout and the withholding of tax on image rights payments.

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