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Issue 1629
Home
Issue
Issue 1629
Issue 1629
28 July, 2023
Analysis
Reviewing HMRC’s consultation on transfer pricing reform
International review for July 2023
HMRC v Part 26A: can you cram the Crown?
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
GE Financial, treaty residence, and the meaning of ‘business’
OECD pillar talk: Pillar Two looming; Pillar One a step closer
EU withholding tax: will things move FASTER?
How to handle R&D enquiries
In conversation with... Dan Neidle of Tax Policy Associates
In brief
Self’s assessment: Inheritance tax
Marano: ‘special circumstances’ in penalty cases
When does a payment constitute a distribution?
News
HMRC manual changes: 28 July 2023
Action required on venture capital schemes, says Treasury Committee
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CIOT responds to CIS proposals
NICs exemption for pension remedy payments
New guidance on tax refunds for negative earnings
HMRC takes control of IPT forms
Reminder of business/non-business test
UK adopts Pillar Two accounting changes
Luxembourg ratifies UK double tax convention
UK agrees social security convention with EEA
Brazil and San Marino tax agreements given effect
CIOT urges caution with trials on 'innovative' tax policy
HMRC consults on tax and occupational health
CIOT and ATT urge clear, comprehensive guidance on taxation for charities
HMRC brings in extra tax from investigations
Government responds to PAC tax compliance report
Agent Update Issue 110
Cases
M R Currell Ltd v HMRC
I Strachan v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
One minute with
One minute with... Jessica McLellan
Trackers
HMRC manual changes: 28 July 2023
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
Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others 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
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC