Tax Journal

Fabian Barth

James Hurst

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.

Ray McCann

Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) considers the practical challenges created by bringing pensions within the IHT net, alongside developments in property taxation, trust transparency and internationally mobile wealth structures.

Jenny Batchelor

Ahmed Mobasshir

The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).

Jenny Tragner

Ali Shokoohi

Promising but flawed? Jenny Tragner and Ali Shokoohi (S&W) examine HMRC’s SME R&D assurance pilot, which offers earlier answers on difficult points but whose lengthy form-led design may create fresh uncertainty.

Liesl Fichardt, Emily Au, Julius Konstantin Berling

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) cover the Chancellor’s move to make the foreign PE exemption mandatory, alongside Take 3.9 on film tax relief and the trap of mistaking motive for purpose.