Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Ask an expert
Home
Ask an expert
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
of
28
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: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania