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In brief
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In brief
IN BRIEF
Views on recent developments in tax.
Lineker and the BBC
David Whiscombe
The notion that the IR35 rules are or are not capable of applying to a partnership depending on which partner signs the contract on behalf of the partnership is a surprising one - and will surely be appealed.
Practitioner view: Hybrid and other mismatch rules – double deduction issues
Matthew Mortimer
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Matthew Mortimer (Mayer Brown).
Practitioner view: The corporate interest expense restriction – risk allocation implications
Kitty Swanson
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Kitty Swanson (Mayer Brown).
Practitioner view: The rules recharacterising interest as a distribution – practical issues
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Catherine Richardson (Cadwalader, Wickersham & Taft).
Practitioner view: Unallowable purposes – ascertaining purpose
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Adam Blakemore (Cadwalader, Wickersham & Taft).
Transactions in securities: HMRC delays could cost it £34m
Chris Etherington
A freedom of information request highlights the extent to which HMRC has been enforcing the transactions in securities rules. The findings suggest an inconsistent approach by HMRC, with the average time for action to be taken potentially exceeding the permitted limits and over £34m of tax revenues at stake.
Allowances for UK pensions schemes
Four tax considerations.
The Budget measure on childcare support
The proposed extension of free childcare is great news, but is the eligibility criteria fair?
Spring Budget 2023: diminished expectations
Duncan Weldon
Jeremy Hunt hit a milestone this week by delivering his first Budget. Once upon a time, a chancellor delivering the annual Budget would be entirely unremarkable, but given his two predecessors did not last long enough in office to do so, the event...
Spring Budget 2023: some thoughtful tinkering
Jemma Dick
The Budget was a little on the boring side, but perhaps that is only because all the main policies had already been trailed? Not that anybody should be complaining nobody becomes a tax adviser because they are of the view that if you're not...
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194
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: 29 November 2024
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
MOST READ
Read all
R (oao Refinitiv Ltd and others) v HMRC
UK signs new double tax treaty with Romania
Self’s assessment: Reforms to APR
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
HMRC manual changes: 22 November 2024