GROUPS

David Harmer

A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal decision in Lloyds Asset Leasing Ltd.

Maddy Potthast

Gavin Little

Continuing the series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) explain the rules for capital gains groups and the pitfalls to watch out for in practice.

Yousuf Chughtai

Davinder Sahota

Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision which shows how complex and large structures can be considered to function as plant for capital allowances purposes, even where other premises-like functions may exist.

Freddie Schwier

Dominic Foulkes

Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.

Helena Kanczula

When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.

Brin Rajathurai

Murray Clayson

Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.

Johan Barros

The progress of the European Commission’s proposal for public country by country reporting depends on whether it is regarded primarily as a tax or a company law matter.

Rupert Shiers

Jonathan T Stoel

The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).