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In brief
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In brief
IN BRIEF
Views on recent developments in tax.
More on the Supreme Court’s decision in PGMOL
No new law, just clarifications.
A bad Apple ruling
Dr Richard Collier
The judgment raises several fundamental – and highly problematic – legal issues, including the misapplication of the AOA branch profit allocation rules.
Millionaire migration
Chris Etherington
Fact or fiction?
The Supreme Court’s decision in PGMOL
Rebecca Seeley Harris
A bit of an anti-climax.
Self’s assessment: Business Tax Roadmap
Heather Self
The Chancellor’s promise of a Business Tax Roadmap next month is welcome news, but let’s hope Reeves looks more widely than just the rate of tax.
Recognising ‘imported losses’ under the loan relationship rules
Lessons from the UK’s first reported case.
Suspended penalties
Peter Vaines
Why HMRC should suspend more penalties for careless error.
R&D claim notification
Emma Rawson
Don’t miss the deadline.
The everyday economy
Julian Feiner
Has the chancellor already given us an indication of some of the bold measures we can expect in the Budget?
Cleaning up: tax on gifts
David Whiscombe
Great job or great person?
Go to page
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194
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
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers