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Autumn Budget 2024: private capital
Elena Rowlands
Ian Zeider
Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) consider
the impact on the private capital sector, focusing on the changes announced to
the taxation of carried interest.
Aramark Ltd v HMRC
FTT upholds HMRC’s application of NIC host employer provisions.
Mainpay Ltd v HMRC
Travel expenses reimbursed by umbrella company to workers were taxable.
Other cases that caught our eye: 2 August 2024
Court of Appeal rules that automated notices are valid: In P Marano v HMRC [2024] EWCA Civ 876 (26 July), the CA dismissed the taxpayer’s appeal that the UT erred in holding that FA 2020 s 103 rendered it unnecessary for HMRC to prove the...
Other cases that caught our eye: 7 June 2024
Non-domiciles and remittance basis of taxation: In A Alimahomed v HMRC [2024] UKFTT 432 (TC) (23 May 2024), the FTT allowed part of the taxpayer’s appeal, finding that a discovery assessment in relation to the 2015/16 tax year was not valid...
An entrée before the manifesto main course?
Chris Sanger
This Parliament’s last Spring Budget delivered on a number of political objectives, as well as setting the scene for the future, writes Chris Sanger (EY).
S Thompson v HMRC
Inaccuracies were careless but not deliberate.
Planning for the merged R&D regime
Carrie Rutland
James Rolfe
Carrie Rutland and James Rolfe (BDO) highlight practical issues concerning
the introduction of the new scheme which takes effect from April.
PD and MJ Ltd (in members' voluntary liquidation) v HMRC
IR35: FTT fails to follow earlier decision on employment status.
CT deductions for cash cancelled or net-settled share options
Lorna Jordan
Alison Hughes
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
Reporting of offshore interest
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC