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ANALYSIS
Cutting edge analysis on tax issues.
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Dominic Robertson
Deepesh Upadhyay
Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson
(Slaughter and May) examine one of the most important withholding tax
cases in years.
Selling an EOT-owned company: when can it be done and what are the consequences?
David Pett
David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider
what is in the best interests of the beneficiaries as a class, how the sale
proceeds are to be distributed and the tax consequences of any sale.
When does the ratio of a judgment have no precedential value?
Michael Ridsdale
Gemma Williams
Exceptions to the doctrine of precedent do exist but, as a recent case
illustrates, they will be rarely applied in practice, write Michael Ridsdale and
Gemma Williams (Wedlake Bell).
Private client review for May 2024
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases
concerning entrepreneurs’ relief, PPR and SDLT.
The taxation of carried interest: where are we now?
Ben Symons
The taxation of private equity executives has become highly politically contentious as we head into the next election. An Opposition policy costing document released in February this year (bit.ly/4dol4do) shows that the Labour Party plans to tax the...
Non-dom reform: the proposals
Rebecca Sheldon
Rebecca Sheldon (Old Square Tax Chambers) considers the proposals from the Conservative Party that give a broad indication as to how the new regime is intended to operate, and what might be expected if the Labour Party wins the General Election.
The post-election (anti-avoidance) enforcement landscape
Ross Birkbeck
With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
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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: 8 November 2024
National Farmers' Union calls for reversal of IHT reforms
New and updated HMRC guidance on R&D
ViDA proposals agreed by ECOFIN
HMRC issue guidance on VAT returns for those exempt from MTD for VAT
CASES
Read all
Collins Construction Ltd v HMRC
M Murphy and another v HMRC
Procurement International Ltd v HMRC
Other cases that caught our eye: 8 November 2024
GCH Corporation Ltd and others v HMRC
IN BRIEF
Read all
CGT anti-forestalling measures
Close companies: take care
Pensions tax changes in the Budget
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
MOST READ
Read all
GCH Corporation Ltd and others v HMRC
Pensions tax changes in the Budget
CGT anti-forestalling measures
Collins Construction Ltd v HMRC
Autumn Budget 2024: IHT - APR and BPR reform