The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.
Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.
There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).
In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.
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