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Hmrc
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Hmrc
HMRC
Hely-Hutchinson: was HMRC merely unfair or ‘conspicuously unfair’?
Michael Sherry
What is ‘conspicuously unfair’? The Court of Appeal disagrees with Whipple J, but Michael Sherry (Temple Tax) thinks it was unfair.
Private client briefing for September 2017
Andrew Goldstone
Nicola Simmons
Andrew Goldstone and Nicola Simmons (Mishcon de Reya) provide the monthly update on the taxation of private clients.
The GAAR panel’s first ruling: a reasonable decision?
Heather Self
Heather Self (Pinsent Masons) looks at the implications of the GAAR panel’s first ruling, and considers what we might expect from future rulings.
Supreme Court upholds barring order against HMRC
Gary Barnett
Heather Rowlands
Heather Rowlands and Gary Barnett (Simmons & Simmons) review
BPP Holdings
and its practical implications for the standard of conduct to be expected of HMRC and other public bodies when conducting litigation.
HMRC’s guidance on the company winding up TAARs
Pete Miller
Pete Miller (The Miller Partnership) is critical of HMRC’s long-awaited guidance.
Making tax efficient
Tina Riches
Following significant changes to HMRC’s making tax digital plans, Tina Riches (Smith & Williamson) reviews what is now proposed and what it means for businesses.
The diverted profits tax: two years on
Nick Gurteen
Mario Petriccione
Mario Petriccione and Nick Gurteen (KPMG) consider the impact of DPT for multinationals operating in today’s global business environment and the need to comply with the increasing tax administrative burden.
Ingenious Film Partners 2: whether deductions are capital or revenue in nature?
Lee Ellis
Lee Ellis (Stewarts Law) analyses the tribunal’s supplemental decision that ‘the rights’ to income from the investments made by the Ingenious LLPs were capital in nature and its likely contentious future.
A heretical view of tax simplification
Sam Mitha CBE
Sam Mitha CBE (formerly of HMRC’s Central Tax Policy Group) believes that simplification should be focused on making it easier for taxpayers to comply with the rules, rather than attempting to simplify legislation.
Why I’m challenging Uber
Jolyon Maugham
Jolyon Maugham QC (The Good Law Project) explains why he has issued proceedings in the High Court against Uber to ensure that it pays VAT on supplying transportation services.
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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