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JUST-AND-REASONABLE-APPORTIONMENT


Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim. 
Jake Landman (Pinsent Masons) examines the Court of Appeal decision and its wider implications.
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
What is a just and reasonable apportionment of profits as an alternative to time apportionment?
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