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INCOME-TAX


Court of Appeal confirms that treatment of final PIP awards are liable to income tax.
Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers. 
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why returning to the UK after a period of non-tax residence is not for the faint hearted.
Taxpayer wins finely balanced IR35 case remitted from Court of Appeal.
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.
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