Editor's pick from August and September

Here’s is my personal pick of Tax Journal highlights for the last couple of months:

1. Q&A with HMRC’s Solicitors Office: Gill Aitken, HMRC’s General Counsel and Solicitor, talks about the role of the Solicitor’s Office.
2. 20 questions on the diverted profits tax: Finance Act 2015 introduced a new tax on diverted profits from 1 April 2015 that has potentially wide application to both UK and non-UK business with activities in the UK. Ben Jones and Cathryn Vanderspar (Eversheds) take stock of the new tax.
3. Lloyds Bank Leasing: the ‘main objects’ test: Heather Self (Pinsent Masons) reviews Lloyds Bank Leasing (No. 1) Ltd v HMRC, which examines whether the obtaining of capital allowances was one of the main objects of a transaction. 
4. Rowe and accelerated payments: ‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.
5. Judicial review and tax: Gideon Sanitt (Macfarlanes) considers the rise in judicial review applications against HMRC, and the difficulty for taxpayers in holding HMRC to account.
6. Private client briefing for September: In this month’s briefing, Andrew Goldstone and Jeffrey Lee (Mischcon de Reya) review the key developments in the private client arena, including the recent decisions in Scott, Blackwell, Ames, Fountain and HCS Trustees.
7. How would the proposed tax tribunal fees impact taxpayers? As part of a package of measures, the Ministry of Justice (MoJ) is proposing to introduce a split-fee structure for the Tax Chamber of the First-tier Tribunal or the Upper Tribunal (Tax and Chancery). Nick Skerrett (Simmons & Simmons) comments  on what's proposed.
8. Larentia: the aims and broad logic of the Directive: Larentia + Minerva is a seismic shift in the recovery of VAT on costs incurred in the acquisition of subsidiaries. Michael Conlon QC and Rebecca Murray (Temple Tax Chambers) report.
9. Intercompany transfer of internally generated goodwill: Jackie Wheaton (Moore Stephens) answers a query on how the internally generated goodwill in an intercompany transfer is treated for tax purposes.
10. One minute with...Amanda Brown: Personal refelctions from the head of tax litigation at KPMG.

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With thanks, as always, to our contributors. If there is a topic you'd like us to cover, please get in touch by emailing me at paul.stainforth@lexisnexis.co.uk.

Coming in October – BEPS, Corbynomics, the proposals on non-doms and more…

Regards,

Paul Stainforth
Editor, Tax Journal