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ANALYSIS
Cutting edge analysis on tax issues.
What is the UK tax treatment of Dubai (DIFC) Foundations?
Kyra Motley
Will Timbrell
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
David Wilson
Jack Jones
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...
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?
Deepesh Upadhyay
Dominic Robertson
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).
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EDITOR'S PICK
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
1 /7
SDLT: gardens, grounds and grazing
Max Schofield
2 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
3 /7
A capital blow for deducting management expenses
Kyle O'Sullivan
4 /7
VAT on private school fees: 10 takeaways
Etienne Wong
5 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
6 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
7 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
A capital blow for deducting management expenses
Kyle O'Sullivan
VAT on private school fees: 10 takeaways
Etienne Wong
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
NEWS
Read all
Business Tax Roadmap: stability is key, says CIOT
HMRC’s new transfer pricing guidelines ‘suggest more aggressive approach’
R&D information requirements revised
Fractional shares in ISAs to be allowed
CIOT seeks clarity on ‘ordinary share capital’
CASES
Read all
European Commission v Ireland and others
HMRC v Professional Game Match Officials Ltd
Muller UK and Ireland Group LLP and others v HMRC
K McCabe v HMRC
Joined Cases
IN BRIEF
Read all
A bad Apple ruling
Millionaire migration
The Supreme Court’s decision in PGMOL
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
MOST READ
Read all
HMRC manual changes: 13 September 2024
Budget Responsibility Bill enacted
Self’s assessment: Business Tax Roadmap
Recognising ‘imported losses’ under the loan relationship rules
Suspended penalties