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Just and reasonable apportionment
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Just and reasonable apportionment
JUST-AND-REASONABLE-APPORTIONMENT
Arguments before the Court of Appeal in BlackRock: is ‘just and reasonable’ a second bite of the cherry?
Neil Fletcher
Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
The super-deduction and SR allowance: claims on construction projects
Paul Farey
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.
Total: just and reasonable profit apportionment
Jake Landman
Jake Landman (Pinsent Masons) examines the Court of Appeal decision and its wider implications.
Tax and the City review for November 2020
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Allocating profits between accounting periods
Chris Lallemand
What is a just and reasonable apportionment of profits as an alternative to time apportionment?
EDITOR'S PICK
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
1 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2 /7
2024: that was the year that was
Jemma Dick
3 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
4 /7
The tractor tax
Stuart Maggs
5 /7
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
6 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
7 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
NEWS
Read all
HMRC manual changes: 17 January 2025
Tax investigations windfall for Chancellor
EU FASTER Directive published
CIOT highlights risks of proposed NICs changes
Making Tax Digital: updated guidance and new awareness events
CASES
Read all
HMRC v Yorkshire Agricultural Society
The Mersey Docks and Harbour Company Ltd v HMRC
Bridgecom International Ltd v HMRC
Other cases that caught our eye: 17 January 2025
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
IN BRIEF
Read all
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
MOST READ
Read all
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
M R Currell Ltd v HMRC
Chemidex Generics Ltd v HMRC
NHS Mid & South Essex ICB and others v HMRC
Tax exemption for LGBT Financial Recognition Scheme payments