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Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
Is payroll closely connected to welfare work for VAT purposes?
Victor Cramer
Victor Cramer (Stewarts) writes about the potential wider impact of the
Cheshire Centre for Independent Living
decision on payroll services in the care
sector, and questions whether the decision is correct.
Newey redux
Etienne Wong
Barrister Etienne Wong (Old Square Tax Chambers) examines the lengthy litigation that still leaves a number of outstanding questions.
Civil or criminal proceedings for serious fraud?
David Sleight
David Sleight (Kingsley Napley) examines a recent Upper Tribunal decision which is important for both tax and criminal litigators alike.
EU’s financial transaction tax: where are we now?
The wrong track or the wrong tax?
Newey: a gypsy’s warning
Michael Conlon KC
Michael Conlon QC (Temple Tax Chambers) considers what can be learnt from the recent Court of Appeal decision.
IR35 lessons from Ackroyd and MDCM
Liz Wilson
It is difficult to discern any guiding principles on the application of the IR35 rules from these two latest cases, writes Liz Wilson (Squire Patton Boggs).
Fowler: a deep dive into tax treaties
Heather Self
Heather Self (Pinsent Masons) examines a recent decision that sets out some important principles about the approach to the interpretation of tax treaties.
Smith & Nephew: a rare taxpayer win on ‘fairly represent’
Heather Self
Heather Self (Pinsent Masons) examines the FTT decision where a UK
corporate taxpayer succeeded in an argument about loan relationships or
financial instruments against HMRC.
The increased importance of the Upper Tribunal
Hui Ling McCarthy KC
The role of the Upper Tribunal (UT) in tax appeals has assumed an increased importance, writes Hui Ling McCarthy (11 New Square).
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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
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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