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PARTNERSHIPS
LLPs and intangibles: avoiding traps in M&A and intra-group transfers
Gregory Price
Lucy Urwin
Gregory Price and Lucy Urwin (Macfarlanes) discuss the challenges of dealing with LLPs in the context of M&A and group reorganisations in light of recent case law.
Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
Deciphering the leaseholder: beating HMRC’s odd habit
Chris Nyland
HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Significantly influential: the BlueCrest salaried members appeal
Amanda Hardy QC
Oliver Marre
The result of the
BlueCrest
appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
Ask an expert: Guernsey limited partnerships - the transparency trap
Matthew Shayle
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
Mixed member partnerships rules: a complex knot to untangle
Liesl Fichardt
Emily Au
HMRC’s approach and recent tribunal decisions on mixed member partnership taxation have led to some uncertainty for individual and corporate partners. Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan) assess the current state of play and what can be done to minimise risks.
Back to basics: SDLT and partnerships
Paul Beausang
Anisha Polson
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
Odey and Hffx: partnerships with mixed membership
Helen Coward
,
Guy Bud
,
Hugh Gunson
Helen Coward, Guy Bud and Hugh Gunson (Charles Russell Speechlys) examine two decisions that raise interesting points of law relating to remuneration arrangements in partnerships with individual and corporate membership.
BlueCrest and partnership taxation: presents under the tree
Andrew Howard
Andrew Howard (Ropes & Gray) examines the decision that covers some
fundamental questions of UK partnership tax.
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75
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