ANALYSIS

Cutting edge analysis on tax issues.

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.

Nicola Simmons

Nicola Simmons (Mishcon de Reya) examines the new tax reliefs introduced to promote more film production in the UK.

Bryn Reynolds

A recent FTT decision provides a startling level of insight into HMRC’s decision making process, writes Bryn Reynolds (Pinsent Masons).

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).

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.

Emma Rawson

The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.

Damiano Sogaro

Edward Reed

Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.

Philippe Gamito

Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).

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.

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).

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