ANALYSIS

Cutting edge analysis on tax issues.

Claire Weeks

The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).

Gideon Sanitt

Sophie Rhind

Gideon Sanitt and Sophie Rhind (Macfarlanes) review the decision in Cooke and its relevance for taxpayers of the FTT’s ability to consider rectification and rescission arguments.

Constantine Christofi

The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).

Ben Lee

In a sector reliant on software for tax solutions, Ben Lee (Andersen) explores the dangers of placing too much faith in ‘tax calculators’.

Tim Sarson

Your monthly review of latest developments, by Tim Sarson (KPMG).

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Heather Self

In this series, Heather Self examines tax issues in the headlines of the national press. This week, she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what the parties say they won’t do, rather than what they will.

Liz Hudson

Jane Duncan

Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of the main parties – with additional comment from the IFS and Tax Policy Associates.

Matthew Greene

Following a recent case, we can probably expect HMRC to be less flexible on taxpayer requests for more time to comply with information notices, writes Matthew Greene (Stewarts).