CAPITAL-GAINS

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...

Artem Vasyutin

Sophie Hatton

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

Heather Self

Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).

Martin Shah

Martin Shah (Simmons & Simmons) reviews the proposed reserved investor fund regime, while Melville Rodrigues (Apex Group) says why it is needed.

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Julia Lloyd

Susie Brain

Julia Lloyd and Susie Brain (Norton Rose Fulbright) provide an overview of the new regime and suggest practical steps that should be taken by taxpayers.

Allan Cinnamon

Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments.

Pete Miller

Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case

Thomas Dalby

Thomas Dalby (Gabelle) answers a query on a client that acquired, and now wishes to dispose of, a company with a UK-resident EBT holding a number of shares

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