Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual
Lee Squires and Fiona Bantock examine recent developments, including the decisions in Banco Mais, Lok’nStore, Norseman Gold and African Consolidated Resources, and TOGC changes
Sometimes HMRC changes its mind after expressing its view to a taxpayer. But what if its original view represented an agreement? Rupert Shiers identifies practical points surrounding this issue from a recent tribunal decision
Matthew Wentworth-May explains how to spot the relevant VAT issues and what the impact is on the drafting of the contract.