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Tax policy & administration
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Tax policy & administration
TAX POLICY ADMINISTRATION
HMRC v Part 26A: can you cram the Crown?
Lisa Rickelton
,
Alex Lewis
,
Abby Martin
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Stuart Walsh
Nuel Oji
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
,
Mitchell Fraser
Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
EU withholding tax: will things move FASTER?
Paul Radcliffe
,
Reinhart Devisscher
,
Ramzan Bashir
Current EU withholding tax procedures are costly, inefficient and prone to fraud. Is the Commission’s ‘FASTER’ proposal the answer? Paul Radcliffe, Reinhart Devisscher and Ramzan Bashir (EY) investigate.
A tougher approach at HMRC, but at what cost?
Ray McCann
Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.
The first 100 days as a head of tax
Peter Mason
Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days.
Getting closure: the FTT’s approach in Hitchins
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal
will exercise its power to direct HMRC to issue a closure notice in light of the
recent case of
Hitchins.
The Windsor Framework and tax: same building, but a major renovation
George Peretz KC
There is no doubt that the current UK government has achieved real changes to the Protocol that will reduce a number of the tax and customs issues, as George Peretz KC (Monckton Chambers) explains.
Reflections on the state of tax today
Robert Maas
A longer tax code and a more punitive tax authority. On his retirement after working in tax for almost 60 years, Robert Maas (formerly Carter Backer Winter) reflects on the evolution of the UK tax landscape.
ChatGPT: crossing the Rubicon?
Paul Aplin OBE
Paul Aplin OBE (former ICAEW president) discusses the new world of
conversational artificial intelligence and its potential impact on the profession.
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579
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