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Crown preference
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Crown preference
CROWN-PREFERENCE
The resurgence of crown preference: the dog in the manger
Eloise Walker
Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).
HMRC v Part 26A: can you cram the Crown?
Abby Martin
Lisa Rickelton
Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
The return of Crown preference
Eloise Walker
A failure to learn from history? Eloise Walker (Pinsent Masons) comments on a Budget measure concerning tax and insolvency.
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: 1 November 2024
Chancellor targets businesses with CGT and IHT reforms
Spotlight on LLPs and disguised remuneration arrangements
New HMRC guidance for taxpayers on rental income
Land transaction tax in Wales: relief for special tax sites
CASES
Read all
GCH Corporation Ltd and others v HMRC
Abbeyford Caravan Company (Scotland) Ltd v HMRC
S Lefort v HMRC
Other cases that caught our eye: 1 November 2024
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
IN BRIEF
Read all
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
Autumn Budget 2024: private equity reforms - a mixed bag
Autumn Budget 2024: non-doms - the end of an era
Autumn Budget 2024: nothing too scary about CGT
MOST READ
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Pillar Two and funds: there is no panacea
One minute with... Paul Rosser
Government to consult on new corporate re-domiciliation regime