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INCOME-TAX


If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Mark Ward (BDO) explains the qualifying conditions, benefits for investors and practical points when claiming relief.
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and other policy measures published this week.
Sarah Gabbai (McDermott Will & Emery) proposes five reforms that aim to increase revenues and simplify the UK tax system.

Sarah Hewson (EY) explains the extent of the tax exemptions on home working equipment.

Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent tax developments affecting private clients.
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open. 
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