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ANALYSIS
Cutting edge analysis on tax issues.
Film tax reliefs: HMRC roll out the red carpet
Nicola Simmons
Nicola Simmons (Mishcon de Reya) examines the new tax reliefs introduced
to promote more film production in the UK.
Go City: end of the road for ‘protective assessments’?
Bryn Reynolds
A recent FTT decision provides a startling level of insight into HMRC’s
decision making process, writes Bryn Reynolds (Pinsent Masons).
International review for September 2024
Tim Sarson
The Irish Apple state aid case and the US electoral candidates respective tax
policies are among the recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Corporation tax rate complexities for corporate LLP members
Emma Rawson
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Private client review for September 2024
Damiano Sogaro
Edward Reed
Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Tax and the City review for September 2024
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
Go to page
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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