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Anti avoidance
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Anti avoidance
ANTI-AVOIDANCE
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
HMRC v Delinian Ltd (formerly Euromoney Institutional Investment plc)
Court of Appeal confirms share exchange anti-avoidance rule did not apply.
The saga continues: implementing Pillar Two in the UK
Jack Gifford
Chris Sanger
The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and
Jack Gifford (EY).
The first year allowance (or full expensing)
Andrew Green
Lawrence Wild
Andrew Green and Lawrence Wild (FTI Consulting) discuss the latest
temporary investment incentives.
The VAT review for April 2023
Bryn Reynolds
Gary Barnett
Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover a number of decisions which indicate the existence of a separate but parallel universe of VAT.
Back to basics: SDLT and partnerships
Anisha Polson
Paul Beausang
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
Debt restructuring: deemed releases
Paul Pritchard
The impact of the pandemic may necessitate a financial restructuring of a company’s liabilities. Paul Pritchard (FTI Consulting) provides a practical guide to the tax issues surrounding deemed release rules.
The UK asset holding company regime: what’s proposed
Elena Rowlands
Ian Zeider
Cathryn Vanderspar
Elena Rowlands, Cathryn Vanderspar and Ian Zeider (Travers Smith) are hopeful that the government will seize the opportunity for positive change to support the UK’s funds industry.
The consultation on VAT grouping
Daniel Johnson
Chris Chatting
Daniel Johnson and Chris Chatting (Deloitte) consider why this issue has
been raised now and what the future changes might be.
Legislation day highlights
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and
other policy measures published this week.
Go to page
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7
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
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC