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ASK AN EXPERT
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.
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Ask an expert: UK IHT issues for US revocable trusts
Jane Johnson
Jane Johnson (Birketts) advises on the IHT consequences of a US trust for US citizens moving to the UK.
Ask an expert: Offshore trusts and trustee borrowing
Julie Howard
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
Ask an expert: Can HMRC override its own statutory review?
Constantine Christofi
Constantine Christofi (RPC) examines the legal and practical issues.
Ask an expert: NRCGT rebasing
Sarah Squires
Sarah Squires (
Old Square Tax Chambers) considers how the
rebasing rules apply to a recent non-resident's plans to sell
UK buy-to-let properties.
Ask an expert: UK company preparing for a Nasdaq listing
Colin Hailey
Colin Hailey (Confluence Tax) outlines two options.
Ask an expert: Plastic packaging tax: ‘finished’ products and exports
Jannine Nicholas
Helen Mackey
Helen Mackey and Jannine Nicholas (Eversheds Sutherland) consider the application of the new tax to a UK manufacturer of food packaging.
Ask an expert: Guernsey limited partnerships - the transparency trap
Matthew Shayle
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
Ask an expert: Moving a UK limited partnership offshore
Katherine Bullock
There are a wide range of tax considerations for a UK resident limited partner, writes Katherine Bullock (Field Court Tax Chambers).
Go to page
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28
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
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