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ANALYSIS
Cutting edge analysis on tax issues.
Winners and losers under the non-dom reforms
Emma Chamberlain
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
Football agents’ fees and dual representation
Pete Hackleton
David Lloyd
HMRC are taking a tougher line on agents’ fees but on some issues they appear to have misunderstood what happens in practice, write David Lloyd and Pete Hackleton (Saffery).
Tax and the City review for June 2024
Zoe Andrews
Mike Lane
Kwik-Fit
,
Hotel La Tour
and the FTT decision in
Osmond
are among the latest developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
FASTER: a European Withholding Tax Directive
Reinhart Devisscher
Paul Radcliffe
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
Pillar Two: assessing the impact on the UK FTSE 100
Lavina Hassasing
Alistair Nichol
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
Back to basics: Sale of assets at under value
Sadiq Hashmi
Ben Handley
A back to basics guide, by Ben Handley and Sadiq Hashmi (BDO).
What is the UK tax treatment of Dubai (DIFC) Foundations?
Will Timbrell
Kyra Motley
There is no equivalent to a Foundation registered with the Dubai International
Finance Centre Registrar of Companies under English law. How then should
they be treated for UK tax purposes? Kyra Motley and Will Timbrell
(Boodle Hatfield) investigate.
The VAT review for June 2024
Jo Crookshank
Gary Barnett
Two recent CJEU decisions on the deemed supply rules concerning donated
goods and the VAT status of vouchers, as well as the Court of Appeal’s
decision in Hotel La Tour, are among the developments included in this
month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
The rules of deduction: Hotel La Tour
Etienne Wong
What has changed since
BLP
? Etienne Wong (Old Square Tax Chambers) reviews the recent Court of Appeal ruling on VAT deductibility for professional fees incurred on share sales.
New guidance on 1.5% stamp tax charge and s 138 clearances
Jack Jones
David Wilson
After an uneventful Budget and Tax Administration and Maintenance Day, and with little by way of legislative proposals (except for those advising non-doms), some of the most interesting tax developments of recent months have come in the form of...
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines