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ANALYSIS
Cutting edge analysis on tax issues.
The dirty dozen
James Quarmby
The 12 most annoying stereotypes about the world of tax, according to James Quarmby (Stephenson Harwood).
Beneficial ownership: practical applications
Helen Buchanan
Gabrielle Van der Haegen
Matthew Everett
Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.
Tax and the City review for July 2024
Zoe Andrews
Mike Lane
The decisions in
JTI
,
Altrad
and
Burlington
are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Summer 2024
Harry Smith
Adam Craggs
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
Disguised investment management fees: some international aspects
Robert Langston
Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
HMRC’s guidance: what is it good for?
Jack Slater
Sarah Ling
HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).
Objects in the rear view mirror
Andrew Parkes
Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.
The VAT review for July 2024
Gary Barnett
Joao Martinho
Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).
In conversation with... Steve Edge
Steve Edge
Anthony Inglese
Anthony Inglese CB talks to practitioner Steve Edge about his career and the changing world of tax.
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406
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
Autumn Budget 2024: IHT - APR and BPR reform
Tax Journal's 2024 Autumn Budget coverage
CGT anti-forestalling measures
Autumn Budget 2024: non-doms - the end of an era