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IN BRIEF
Views on recent developments in tax.
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Lisa Shipley
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...
Legislation day: practitioners' views
Philip Ridgway
Rebekka Sandwell
Ben Jones
Elizabeth Bradley
Penny Simmons
Eloise Walker
Abigail McGregor
Expert comment on aspects of Legislation day 2023.
Challenging information notices
David Whiscombe
A recent case involving a foreign national illustrates how difficult it usually is to overturn a Sch 36 notice.
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.
Security for tax
Peter Vaines
The recent case of
Horder
shows how tough the security for tax provisions can be.
Stamp duty on share issues
Mike Lane
Has the UK just reintroduced its 1.5% stamp duty charge on share issues?
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.
The consultation on TP, PE and DPT reform
Edward Buxton
Sarah Bond
The government proposed welcome simplifications aligning the UK’s rules more closely with OECD standard.
Mudan: whether property suitable for use as a single dwelling
HMRC takes a firm stance on ‘uninhabitable dwellings’.
ERS refresher
Philip Swinburn
With the 6 July employment related securities reporting deadline fast approaching, here is a reminder of the key rules.
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197
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: VAT on private school fees: a lack of clarity