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Just and reasonable apportionment
Home
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
Mike Lane
Zoe Andrews
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
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
Stage One Creative Services Ltd v HMRC
Other cases that caught our eye: 13 December 2024
L v HMRC
A third route to exit: tax consequences of continuation fund transactions
R Grint v HMRC