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The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).
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.
UK VAT model: stay traditional or go modern?
Rebecca Porter
The sky’s the limit for changes to UK VAT since Brexit broke the EU VAT
shackles, writes Rebecca Porter (The VAT Team). Are radical changes needed?
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
The Retained EU Law Bill: what you need to know
George Peretz KC
The Bill had its second reading in the House of Commons on 25 October. George Peretz KC (Monckton Chambers) looks at what it does and its implications for tax practitioners.
The General Court’s flawed decision on CFC state aid
Paul Davison
Helen Buchanan
The judgment reads as something of a ‘whitewash’, supporting the
Commission on every ground, write Paul Davison and Helen Buchanan
(Freshfields Bruckhaus Deringer).
The FII group litigation: the end of the beginning or the beginning of the end?
Cristiana Bulbuc
Lee Ellis
The Supreme Court has handed down its third judgment in the long-running
FII GLO
case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
Tax and the City review for July 2021
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) report on the recent
developments, including some encouraging findings on the UK’s position as a
leading centre for financial services investment.
State aid and tax rulings: latest developments
George Peretz KC
In May, the EU General Court delivered two judgments on fiscal state aid.
George Peretz QC (Monckton Chambers) explains why they still matter in the
UK in light of the UK’s proposed state aid regime.
Tax and the City review for June 2021
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
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EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
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
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 25 October 2024
Government to consult on new corporate re-domiciliation regime
HMRC revamp guidance on EMI independence test
HMRC confirm delay to new employer reporting requirement
Special tax sites designated in Wales
CASES
Read all
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
R (oao Fluid Systems Technologies (Scotland) Ltd and others) v HMRC
Other cases that caught our eye: 25 October 2024
Panayi v HMRC
BTR Core Fund JPUT v HMRC
IN BRIEF
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
MOST READ
Read all
Panayi v HMRC
Home and away: how to go non-resident after McCabe
HMRC update ERS guidance for Vermilion
BTR Core Fund JPUT v HMRC
ISAs and fractional shares