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ANALYSIS
Cutting edge analysis on tax issues.
Contentious tax quarterly: Autumn 2024
Harry Smith
Adam Craggs
There has been a steady rise in disputes concerning IHT and SDLT, report
Adam Craggs and Harry Smith (RPC).
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The VAT review for October 2024
Jo Crookshank
Gary Barnett
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers cases concerning payments to acquire ‘credits’, VAT groups
and pension funds.
Officials advise, Ministers decide
Lord Macpherson
What Budget advice is the Chancellor likely to receive from the Permanent
Secretary at the Treasury? We asked former Permanent Secretary
Lord Macpherson for his thoughts.
How to handle tax on residential lease extensions
Martin Codd
Chris Holmes
Chris Holmes (BDO) and Martin Codd (Penningtons Manches Cooper)
consider a more cost-effective route for landlords when considering an
extension of a residential lease with their tenant.
Have we lost the ‘art’ in UK tax valuations?
Pavan Singh
Tax valuation methodologies have evolved. Pavan Singh (Eight Advisory)
considers whether the ‘art’ of valuations has been lost to too much ‘science’.
Hughes: a triumph which masks a forensic disaster
Jonathan Fisher KC
Insights into HMRC’s practices in the investigation of an allegedly complex
tax fraud described in the court’s judgment makes for compelling reading, as
Jonathan Fisher KC (Red Lion Chambers) explains.
Freebies
David Whiscombe
Benefits received by reason of a person’s employment are taxable.
David Whiscombe wonders whether that extends to certain gifts made
to government ministers.
Time is tight: CGT and the Autumn Budget
Peter Rayney
Peter Rayney (Peter Rayney Tax Consulting) discusses some strategies for
CGT tax planning in readiness for the upcoming budget.
Ten questions on the Apple judgment
Dominic Robertson
Amaury de Galbert
Does the CJEU’s judgment in
Apple
signify a major shift in tax State aid
cases? Or is
Apple
likely to be a one-off? Amaury de Galbert and Dominic
Robertson (Slaughter and May) investigate.
Go to page
of
416
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: VAT on private school fees: a lack of clarity