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CORPORATION-TAX
Tax grouping (part II): capital gains groups
Maddy Potthast
Gavin Little
Continuing the series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) explain the rules for capital gains groups and the
pitfalls to watch out for in practice.
R&D Disclosure Service: the best route to resolution?
Jon Claypole
Jack Sloggett
Jon Claypole and Jack Sloggett (BDO) welcome HMRC’s new R&D
Disclosure Service but explain it is not suitable in all circumstances.
ScottishPower (SPCL) Ltd and others v HMRC
CA rules that consumer redress payments were deductible for CT purposes.
HMRC’s assessment powers: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
Bureau Workspace Ltd v Advocate General for the Commissioners of HMRC
HMRC’s denial of late R&D claim upheld.
MW High Tech Projects UK Ltd v HMRC
R&D expenditure claim extinguished by going concern condition
.
The taxation of SMEs in 2023
David Whiscombe
Disputes over partnerships, goodwill, distributions and VAT were among some of this year’s key points of interest for SMEs, writes David Whiscombe (BKL).
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
CT deductions for cash cancelled or net-settled share options
Lorna Jordan
Alison Hughes
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Legislation day highlights
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and
other policy measures published this week.
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4
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