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IN BRIEF

Views on recent developments in tax.

When does a payment constitute a distribution?
Card image Matthew Greene
A recent case highlights the difficulties that can arise when the recipient of value from a company is a shareholder.
26 July 2023
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Card image Lisa Shipley
Card image Alison Lobb
On 12 July 2023, the OECD/G20 Inclusive Framework on BEPS (OECD inclusive framework) published an outcome statement on nexus and profit allocation challenges (Pillar One) and global minimum tax rules (Pillar Two). The statement has been agreed by 138...
21 July 2023
Legislation day: practitioners' views
Card image Philip Ridgway Rebekka Sandwell Ben Jones Elizabeth Bradley Penny Simmons Eloise Walker Abigail McGregor
Expert comment on aspects of Legislation day 2023.
20 July 2023
Challenging information notices
Card image David Whiscombe
A recent case involving a foreign national illustrates how difficult it usually is to overturn a Sch 36 notice.
13 July 2023
Why HMRC’s crypto tax proposals fall short of the mark
The problem with not taxing when exiting a DeFi position is that it only works if the tokens returned are of the same type and quantity.
13 July 2023
Security for tax
Card image Peter Vaines
The recent case of Horder shows how tough the security for tax provisions can be.
13 July 2023
Stamp duty on share issues
Card image Mike Lane
Has the UK just reintroduced its 1.5% stamp duty charge on share issues?
5 July 2023
Why HMRC’s crypto tax proposals fall short of the mark
It would be a mistake to treat DeFi rewards as income and to apply repo-like rules, as HMRC proposes, because the quantity and composition of assets redeemed could be different to those originally added to the DeFi position.
4 July 2023
The consultation on TP, PE and DPT reform
Card image Edward Buxton
Card image Sarah Bond
The government proposed welcome simplifications aligning the UK’s rules more closely with OECD standard.
28 June 2023
Mudan: whether property suitable for use as a single dwelling
HMRC takes a firm stance on ‘uninhabitable dwellings’.
28 June 2023
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Generator Power Ltd v HMRC
20 November 2024
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