Tax Journal

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The carried interest reforms create substantial compliance burdens and may expose internationally mobile investment managers to double taxation, write Aron Joy and Alex Ereira (Weil, Gotshal & Manges).
Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new Mandatory Tax Adviser Registration Manual.
Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.
Claire Logan (Grant Thornton) explains why estoppel and abuse of process are increasingly relevant in VAT disputes and how they can materially affect how cases are argued and resolved.
Pillar Two filing, an AG opinion on the EU anti-abuse rule and Budget measures in Australia and New Zealand are among the developments in this month’s review, by Tim Sarson (KPMG).
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.
‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.
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