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CROSS-BORDER
FASTER: a European Withholding Tax Directive
Reinhart Devisscher
Paul Radcliffe
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
The VAT review for November 2023
Katie Oliver
Gary Barnett
This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers the Supreme Court decision in
Target Group
, the CJEU ruling on ‘free gift’ promotions, the potential use of split payments in the collection of VAT and the draft legislation intended to ensure stability on the interpretation of VAT and excise laws.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Dilpreet K. Dhanoa
Philip Baker KC
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
DAC 6 update: UK narrows scope of mandatory reporting
Sandy Bhogal
Avi Kaye
Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.
Key issues for in-house tax teams: a checklist
Mark Ellis
James Egert
Chris Holmes
Chris Holmes, Mark Ellis and James Egert (BDO) set out important current corporate and employer tax issues which in-house tax teams should now be addressing.
HMRC’s final guidance on DAC 6: a good first attempt?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) discuss the published guidance that still leaves many key questions around the scope of DAC 6 reporting obligations.
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
Trade remedies: the new UK regime
George Peretz KC
After Brexit, the UK will operate its own system of trade remedies.
George Peretz QC (Monckton Chambers) examines what’s proposed.
Taxation of credit funds: from one crisis to another
Lily Teh
Will Smith
Will Smith and Lily Teh (
White & Case) consider
some of the major trends and tax issues relevant to the establishment and operation of credit funds.
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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
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines